Text

Part 1 of 2, North Anna Power Station, Units 1 & 2, Proposed Improved Technical Specifications, Request for Additional Information (RAI) Section 3.6 (Tacs Nos. MB0799 & MB0800) Miscellaneous Dominion Changes to Its Submittal
	ML020510089
Person / Time
Site:	North Anna
Issue date:	02/11/2002
From:	Hartz L; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	01-281B, CM/RAB R0, TAC MB0799, TAC MB0800
	Download: ML020510089 (170)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 11, 2002 U.S. Nuclear Regulatory Commission Serial No.: 01- 281B Attention: Document Control Desk CM/RAB RO Washington, D.C. 20555 Docket Nos.: 50-338 50-339 License Nos.: NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED IMPROVED TECHNICAL SPECIFICATIONS REQUEST FOR ADDITIONAL INFORMATION (RAI)

SECTION 3.6 (TAC NOS. MB0799 AND MB0800)

MISCELLANEOUS DOMINION CHANGES TO ITS SUBMITTAL This letter transmits our additional responses to the NRC's Request for Additional Information (RAI) regarding the North Anna Power Station (NAPS) Units 1 and 2 proposed Improved Technical Specifications (ITS). Also, this letter transmits miscellaneous changes to the submittal that are a result of internal comments. The North Anna ITS license amendment request was submitted to the NRC in a December 11, 2000 letter (Serial No.00-606). The NRC requested additional information on ITS Section 3.6 in a letter dated April 23, 2001 (TAC Nos. MB0799 and MB0800). Dominion submitted responses to the NRC's RAIs in a letter dated June 18, 2001 (Serial No.01-281). After reviewing Dominion's responses, the NRC requested additional information. This letter transmits the additional information that was requested, in addition to the miscellaneous changes to ITS submittal that are a result of internal comments.

Attached are the NRC's RAIs, our responses to the RAIs, and the revised pages of the submittal, which complete our responses to the subject RAIs. Following the responses to the NRC's questions is a summary of the changes that are not associated with the NRC's questions, and the affected ITS submittal pages.

If you have any further questions or require additional information, please contact us.

Very truly yours, Leslie N. Hartz Vice President - Nuclear Engineering Attachment Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303-8931 Mr. Tommy Le U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 12 H4 Rockville, MD 20852-2738 Mr. M. J. Morgan NRC Senior Resident Inspector North Anna Power Station Commissioner (w/o attachments)

Bureau of Radiological Health 1500 East Main Street Suite 240 Richmond, VA 23218 Mr. J. E. Reasor, Jr. (w/o attachments)

Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060

SN: 01-281B Docket Nos.: 50-338/339

Subject:

Proposed ITS - RAI - Section 3.6 COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this 1 1th day of February, 2002.

My Commission Expires: March 31, 2004.

SNotary Public (SEAL)

Attachment Proposed Improved Technical Specifications Responses to Requests for Additional Information ITS 3.6, "Containment Systems" Virginia Electric and Power Company (Dominion)

North Anna Power Station Units I and 2

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.1 Containment Discussion of Changes (DOC) A.8 (CTS 1.0)

(3.6.1-1) CTS 1.6 CTS 3/4.6 ITS 3.6.1, 3.6.2, 3.6.3, and Associated Bases NRC RAI: CTS 1.6 defines CONTAINMENT INTEGRITY. A markup of CTS 1.6 is provided in the CTS markup of CTS 1.0, but not in the markup of CTS 3.6. DOC A.8 (CTS 1.0) states that the definition of CONTAINMENT INTEGRITY is deleted from the CTS/ITS. This is not entirely correct. The DOC is incorrect in that the definition is not deleted but is relocated to various Bases in ITS 3.6, which is a Less Restrictive (LA) change. In addition, there are Administrative changes associated with CTS 1.6, which deal with the requirements of the definition being used as the basis for certain SRs in ITS 3.6.1, 3.6.2 and 3.6.3. CTS 1.6, Item 1.6.1 is the basis for ITS SRs 3.6.3.1, 3.6.3.2, 3.6.3.3, and 3.6.3.4; Item 1.6.3 is the basis for ITS 3.6.2, and Item 1.6.4 is the basis for ITS SRs 3.6.1.1 and 3.6.1.2. Refer to Comment Numbers 3.6.1-2 and 3.6.1-3.

Comment: Revise the CTS markup and provide the appropriate discussions and justifications for these Administrative and Less Restrictive (LA) changes.

Response: The Company will take the action proposed in the Comment.

CTS 1.6.1 is marked as part of ITS 3.6.3 adopting the requirement using DOC A.1.

Requirements for CTS 1.6.1 are included as being related to ITS SR 3.6.3.1, SR 3.6.3.2, SR 3.6.3.3, and 3.6.3.4.

CTS 1.6.3 is remarked as part of ITS 3.6.2 adopting the requirement using DOC A.1.

Requirements for CTS 1.6.3 have been marked as part of ITS 3.6.2.

CTS 1.6.4 is remarked as part of ITS SR 3.6.1.1 adopting the requirement using DOC A.1. ISTS 3.6.1.2 is not adopted.

An LA DOC is not used because the material is retained in the ITS, not moved to another document. DOC A.1 is used instead.

CTS Pages in Section 1.0 are marked to describe to which ITS sections the respective requirements are being moved.

Additional Response: Based on verbal comments from the NRC, the portion of the previous response marked with an asterisk is modified. DOC LA.2 is added to document the relocation of CTS 1.6.1 to the 3.6.1 Bases. The CTS markups for ITS 3.6.2 and Section 1.1 are revised to reference this change.

(/:.:ýo ýU&ýFAMOýAePýl 5-5-83 1.0&DEFINITIORS the defined terms of this section appear in capi ze t p and are

~4~~ applicable throughout these Technical Spcfcto 1.1 ACTIObsha beel that part. of a Specification which prescribes G ýu- a eunder desi nated conditions.

AXIAL FLUlX DITT~lC o. dpbiLOI ei 2 S1.2 AXLQ FLUX sall be the difference in normalized flux signals, AF .- ao . ,erween the top and bottom halves o a two section excore neutr t o.

CHANNEL CALIBRATION d1.3 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the 4' Cai,"

C-h channel output such that it responds vitb the necessary range and accuracy to 1 a.* I[known values of the parameter vhich the channel monitors. The CHANNEL CAL:HRA TION shall etcomia the en ecanl ~ ui &Zb apro adac nirI~l,

~uto On and s IE. include FtTNCVT! ' TIST e CHANNIEL tX.L-1YRATION may be performed b an series of sequential.- overlappin8 or total channel steps t tira i is" ý tte. .t CHANNEL CHECK l.4 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, vhere possible comparison of the channel indication ando status vith other indica tions y.orl status derived from Independent instrumentation channels measuring the same parameter. O CHANNEL " TEST P .. 'q L 27)

(7cA 0 1.5 A. shall be.

-the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY I a nct a ns1s

b. stbl chnnl i e iq4eetion o? a si-hated signal Intl ..ýAhe sensor to vertfy OPEfABILIT including alarm.,ind/or tr-11 functi6ns.

Colaier""= .,T- " ...

.. D ONLrIALcN.LNI .LZ!LU&"A e&J"~

All penetrations required to be closed during acciden \ 3t4*

1,6.1 condi tio ns, are eith er: Il ,A-% .6.3-NORTH ANNA- UIT 1 1-1 Amendment No. 10, 4

. CLI ac;ITh rrk If 11 keL. H r C"ýe )

MIS "ku vQ.ec\O KAI 1 bi) 4-22-94

(:

1. DEFiNmONS_(Conhiriuedl selo1;.,1- FýAt 3 System.

Capable orof being diosed by an O~pERABLE containrr'sr atomnalic isolation valve~

Closed by mania valves. bWind flanges. or deactivated aiLzorrialic valvet secured/

in theeir diosed poskiofis. exz~eS tot valves thu(are oOP7ern u~ner aa rarslr~atve corwol as permited by Specihuiio 3.6.3.1.

1.6.2 CAM" qipnur hatche" are closed and ssaieL 1.6. EachkbdSOP ication 3.6.1~z' 1.6.4Th COMB c*anrerg leakage rotes atewf~ithnV* Wfof SpeaMtir, 3.6.1.2j~ <a.J~~b3 ~

or Ofns 1.6.5 (The "seaigflCVfl~

(isRALE assodale-d560 th each (eG

-emln

_____TS ea.o4 r-v AK AM £OprcC k 1.7 0to th the reactor oerswre vessel with the vessel head nwwivoc anid on V*-Mse no CORE ALTERATION "sntial prueJde colrrlation of ovwemom c at& nooneft 1 asae(j.

rMRF OPFPAmmar LI~rrs RFPOR m-_ i Va

1. TeCORE OPERAT04G umrTS REPORT is the wosp~ecft djrmeqg if Wv~e po c~creWne fo the Oj~,w tw I)I bad cycle. These cceeeM ci spe~f4 knws smi Oletemtnd o feach in gcira wit' spacl

,vdr~eer optrbnWti teelmt sadrse inft*bA&J q)K~,rcwb QnCRr- FOI JVALM FIJT .1 1.10 The DOSE EOUJIVALENT 1-131 shalbe iton wr~r~rutonI 1.-131 (rTMxojrws~gm) wtvmh salone would prJoosc the sarr thyrfoi chose gs the IqJarty &rd WK~ IstoJll ci a 1,-131. 1 132. l-133, 1-134 anid 1-135 actually presetS 'The Wthyoid dome conventin fatoors used for ftt~

caim kation "Ia be thoe hooed hin1abi III of TID-14844 'C41culttn of N~uance Fators tar Reacar sier.,z~~j Powe &M79ari 1-.kVEFaF !nisiTnF(-ATINr-m1RGY 3

0c 1.11 Eshall be the a&"fag@ (w*Wzo~d inpcropwbon Io Vie conosrwation of each radi~cnxde in the re actr coolant al the t~irn c( ssnp*i) at the sum of t's average beta anM qanvn eerwrpws per disruagrabkon (fin LAWe) icr kotome, other Vhan liws. with half bves W=rase mta 15 nfwmnes. rnaV up at least 95% of the WWa ronrixoirs aolv~y sinVe coasi.

NORTH ANNA.- UNIT I 1 -2 Arrmdninr~fa o.46,.4l.144, 181 I/ Pell. It' PI-25r e 3 a-F

('.0 IX!E AAVD ,~oLICAroa/

r5-5-83 15 D6E7INITIONS

]T7 Sec *t,*on b heI defined terms of this section appear in capit led type and are aiýpplicable throughout theae Technical SPeCificati~ansý~ jae 1.1 ACTION shall be that part of a Specification vhiEhprescribes~~)A Mau r ;4 =e designated conditions' A4J pf-D- ~ ;~;4 VJAJ.Ph" clees Tan AXMA FLUX DIFFERENlCE f4t~SA ~L(

A D .2 _MiA FLUX DIFFERENCE shell be the difference in normalized flux signals, exP" sspd4in P between the top a~nd bottom halves of a tvo section excore neutronWdetector.

CHANNEL CALIBRATION g II

1.3 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the cle A*c s -. channel output such that It responds with the necessary range and accuracy to 1 cýh the channel monitors. The BA 4j aown values of the paraneter kn" /1,12

~4,.- ON shall encom a t he sml hbannal.

7 INLn ah CRNE trl Iun ctip , u '1Iclude .w CALIBRATION any be performed bFy -anyseries of sequential, overlapping or total 4,+810~JT channel steps Jxy 4 n1t te E ffs rate CHANNE CHECK 1.1. A CHAKNNEL CHECK shall be the qualitative asses~sment of channel behavior during operation by observation. This determination shall include, where pcossbibaj,,comparison of the channel indication an~zý status with other indi ca tions 4gi~)r status derived from independent instrumentation channels measuring the same parameter. b-e 4 CRANNEL TS OPE RA T 'ML (COT 1.5 A (5F5ig USnCTM3n,eiQ shall bet)

C*aoi the injection of a si1-1ateed signal into the channel as close to the sensor as practicable to verify OPERAJILIM TT.6E: LA.~

b. sta le c ~annl,9 t a. ecto oa aa ,ted +/-gal a z thea semsor tin aerif OEAEIT cldng-'alarm and/or trip ftcr~os

( ONTAINMMNT UqTGRITT 1.6 CONT-AINKE IN7ECRITV- shall exist when*ee7 I2S6.IIi"f I'I,

'ii LA during accident I I w4reA to be closed conditions~V-M ar ihr:-' .bit 3- I NORTH ANNA - UNIT 2 11Amendment No. 3 WillI c~

(PV' :rTS Vo I e DEFINITONS (C-0ftinud) contanmmr auomatic isolhion valve Cpabe o beng j0Wby an OPRBE a.

I Isystem.

iedhI* or

ýýec valves secured Eb. Cosied by manual valves. blind fiage.sor deaaoi~ed autoratic aammzisirative in thO' ciosed postE.s except tot' valves thai are open urxer woroasI emale

<$et. T-5 3, b' 1.6.3 Eac a" ERABiL'E'.. p"5m`uain to..13 1.6.4 (m~e contaimetTr isaimAge raiss are Ma___of__

(S.4. TS 3.1,i aidWit Pe *c4 weti behows or 0-rings))

The seabn ff10T isOP:ERAB45 Z..

X_

wwerin*ýý_- 10

ý.el, _soLo~f y~cA

.~r*m AnWh 128 CORE ALTERATION SWaf be fth" rrOMn!qiiiTG ay OE rq&=O pressu~re vessel w1th thvess I heand rernoved end %We in the vesl aupmv&~n Or CORE ALTERATION SWaj not Pr*CUU* completionflat rIswIT GIt WffprWf 10 81 ate 01 -I IIMMT RFPO (3Tj P0iY~r1

&X tDE PERAT1N!

1.9 The CORE OPERATG LIMITS REP'ORT h Ie Una4snww -W e~ WCM& V 6jj3 *ir~sjý, tor VW we r 4jjmLj0 red m cycle. Thes ycy6-epWc~a with Spet: n Plait linus shot be deitriiied Waeach rebad Cycle in at~oardw op. rartion withinl these ao~ssaed in rdividuaai qxfiec:XWMs nnqF r-outmVA FNT l1-ni 1.10) The DO)SE EOUIVALBJT 1-131 shllbe that wtrWi~ton @11-131 (ftocriesýMm) which akin. wuould produc trig srn. tyroid nsa a= tre Wsarvy an lsopic nwu~rs dti- 1-1.

132. 1-133, 1-134 "n 1-135 &nxwaypreseml The thy, od osecor'ersiontaboorsu!1f'rthit caJimilabo "lla be Uai ksed kiTabitle I 11DT-148".I44 ~Lkwbdn @1D~rsianza Power and lest Rea= SIL.s.j7~~

~~

1-AVFRAGF D ~WFRT!)N FNFRrY 1.11 'E$hap be the avrage tw.etped in proportion o fte consrermtkion o( each radiconuid n theM&= a DcoWtaMMhe15730fW1S1p 5fl)O a suhemoUlofPavesraige betandiparvna

-energies per disirIagratiof (in U.V) 11omoops. othef Van bdinies, with two W'es prower V=a 1S imnuies. makx~in up lea"V 95% of the tota mn-or*iS matvb Inthe woolaft.*

1-2 AnuEnett5 No.Z3,A30 162 NORTH ANNA -UNIT 2 e

Pc~C } / Reo. 0

D-5 3. '. I 5-5-83 1.0 DEFINITIONS The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications.

ACTION 1.1 ACTION shall be that part of a Specification vhich prescribes remedial measures required under designated conditions.

AXIAL FLUX DIFrENCE 1.2 AXIAL FLUX DIFFERENCE shall be the difference in normalized flux signals, "expressed in 2 of RATED THERMAL POWER betveen the top and bottom halves of a two section ecore neutron detector.

CHANNEL CALIBRATION 1.3 A CHANINEL CALIBRATION shall be the adjustment, as necessary, of the to channel output such that it responds vith the necessary range and accuracy known values of the parameter which the channel monitors. The CHANNEL CALIBRA "1,0 TION shall encompass the entire-channel Including.-the naopr. and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL or total CALIBRATION may be performed by any series of sequential, overlapping channel steps such that the entire channel is calibrated.

CHANNEL CHECK 1.4 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall Include, where possible, comparison of the channel indication and/or status vlth other indica measuring tions and/or status derived from independent Instrumentation ch1anels the same parameter.

CRAMEL FUNCTIONAL TEST 1.5 A CHANNEL FUNCTIONAL TEST shall be:

channel

a. Analog channels - the injection of a simulated signal Into the Including as close to the sensor as practicable to verify OPERABILITY alarm and/or trip functions.

i*nto the sensor to verify 0PMEIL*ITT including &Utra and/or trip fu mct'tous.

L b. Bistable ch-in-els - the inection of a simulated allus.

TNTnGRTTT

_C0N'TAIN*T 1 I Lo 3.oJ NORTH ANNA - UNIT 1 1-1 Amendment No. 10, 4 8

'4' RA I t 0.ýc 4 J C>

rr-5 3,611 0K1 lRAI3,.-

kA3T.

- - ,m,mflI3 I,in. 4-22-94 I.v LI 'kAt3: 3 T-~T5 1.6.2 J 1.6.3 1 .64 The CT33jVV1Wft baga fate$ ame w~if the kboftOfSP ~ion 3.L¶.2aw $1-I 1.6.5 o al m~q-lrechanusm 04. wo Oqin h

tCrrffn)l i Ff I FAKiCM ----- -~.. EDt 1.7 CONTROLLED LEAKAGE &Wabe Vwa seW wowe fbw ~IeD Vie f*a&= COOM RAI, 3.4.1-r-nRF At TERATIOPJ 1.8 CORE ALTERATION OWiabe PIe " u w*zjabn Of anW CMVrwr' w~tin the f Ooehri rsaor prosssut vessel With thePvesselI heed renwved WOd WGI in PmS vernl MSPni~mon ml CORE ALTERATION thanl nc prockxe conqietln ml nuvamm of a WicOflf KIo a saeo cowmeaiv N okf mpr- CWFFtATTNM LtUrTR PPPMPT 1.9 Imbthat The CORE OPERATING UIMrTS REPORT b Peusi~e~ domux"Of Pl provie core op"Mmw 6ii" tor Pie awm" operatin mreb cycle. These" la be cetoenmred tar each re ope rulvn wtftn Voss cpernlu kiii be leyd-spue cm op""ain cycle in~ m~manc wkh Specgcztbn "S 1.7 Plait Inme inclvi" sec~caiou

(

DORF FOUIVAI FNT ý1213 1.10 The DOSE EOUIVALEWT 1-131 stiabe Vlwnosivmtbnd 1-131 Inliaowriss~ra"l wtch alone wouW puM" Vw me noVitroild do"e as the qpa7Ky and mb~cwajm 011-131, I-132. 1-133. 1-134 anid 1-135 eSualy pm**Mr The ttlfoid do"e awrweron tacuxs used to Pie cakljtatlon shalI be Pi4ooebd in rable Ul dl TID.14b44. Ca4aiudon of Dkuancs~ Factors I-or Power anid I sto Rew SAW.

=RVFAM:F nIRINTF-MA71eWJ PW=DeZW 11.11 "1habe Pue evvme to*~a in propr~lon mfta Vewcosvaftn of each ra JkwumL fde Sin the re amm WobJ W1 tP VwWrm of w ig) of Pt um o.flPu ft e e beii ari prm.

e nerpies per dminwraialtn (in M.V) r isompes. o~e Vian Wh~et. witi hlf blee greazer tha 15 rrw~es. makkV up W b all 95% of P thea rWts)nw-koý a~oty kiin Vw owL-NORTH ANNA.- UNfT i 1-2 Asmcbmaeru Noa. s,48,3446, 181 pac.t V

I-T-5 b3 5-5-83 Ts5 DEFI :NITIONS 1.0 defined terms 0 t s section appear in capitalized type and are The applicable throughout these Technical Specifications.

ACTION remedia 1.1 ACTION shall be that part of a Specification which prescribes measures required under designated conditions.

AXIAL FLUX DIFFERENCE 1.2 AXIAL FLUX DIFFERENCE shall be the difference in normalized flux signals, expressed in 2 of RATED THERAL POWER between the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION 1.3 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the to channel output such that it responds with the necessary range and accuracy known values of the parameter which the channel monitors. The CHANNEL CALIBRA TION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL be performed by any series of sequential, overlapping or total stepsmaysuch that the entire-ckannal is calibrated.

CALIBRATION channel CHANNEL CHECK channel behavior 1.4 A CHANNEL CHECK shall be the qualitative assessment of This determination shall include, where during operation by observation.

possible, comparison of the channel indication and/or status *ith other indica measuring tions and/or status derived from independent instrumentation channels the same parameter.

CRANNEL FUNCTIONAL TEST 1.5 A CHANNEL FUNCTIONAL TEST shall be:

a. Analog channels - the injection of a simulated signal into the channel including as close to the sensor as practicable to verify OPERABILITY-alarm and/or trip functions. ad channels -the injection of a simualated signal into tha

b. Bistable I

1 exist when:

shall*AI*T1 Ofe<~i KD L-&O 342 d pentratio req uiredt o b ng I

Amendment No. 3 NORTH ANNA - UNIT 2 1-1 RNT RAI i

o/. 1tj 5

4-22-94 12 M 1.0 DEFINMONS (Continued) flvalve vaive* t 1.6.2 1.6.3 air lock is OPERABLE purmuar io

~

5('~~. 1.6.A The corflsinme nitleakage rateS arewi~ithe r*s oibf Specffir.on3.6.1.2 ari 1.6.5 socrvt *~iwm amt pe welcls, bellow*3r 04;1L.

is =tRAI.E I

1.7 I)OtR~CONTROLLED L~ WJAGE shal bet it seal water flow suaie puny seaM.

QDRF A1 TERATION 1.6 DIFAKAGF ID the CORE ALTERATION "Ialbe the rrvveme or mer~ulatlon of any =iinentwr ttin the' reactor pressure vessel with the vessel head removesd anid fke inthe vsseL Muspesimof reactor cool 0

CORE ALTERATION &NIl rnot pre~.ad wflp~tn ofl0 move wme cg a cwortoeni 'oas a&at consevative positio CQPF flPFRAT1NILIMITS REPORT 1.9 The CORE OPERATING UMrrS REPORT isthe w*.specfic doctmeft VWn pnwk -J1T5 core coerwaVn binus for the crram woorafingrel ev~cvde Thm~ -~~u mwm brrwts "hIlbe dleterrmined Wpeachi robed cycle in accofoatce withi Spccto -.. lr ope ration wifthn thes ape ravk knfls a addressed in widwbijWal pechtcatloun DQSF FOLRVAP FNT 1-=3 1.10 The DOSE EOUIVALENT 1-131 shall be that conosrtratio~n of 1-131 (nicrocuwstnie.m) whxch alone wol procluc the sameW thyfoid do". = the CWanity andc soopic nihre at 1-131.1-1 132, 1-133. 1-13.4 a" 1-135 acbuaby preseri. The thyroid does corwenson tactors used fto Vtt~

calm lation "Ia be Uhos listed in lable III of TID-14844,.~ lto of DiMarce Fa lonitr Power and lesi Reactor SiWs.

?-AVFRAcGF nttIN FcGRATic)N FN-Rcty 1.11 'EShall be the average (weigtited in proponion 10 the corwunration of eachi radlorucide tn the reacor cooai at the mm cis~ srin) af the suM 01 the averge ber arnd gammna

.enerpies per disintegration (in LMeV) for sotopes VOthW than iodlnes with half lives greater th=

15 mait~nes. rnaking uip at W=sa 95% of the total non-odine activiy Wi he coolaint.

NORTH ANNA.- UNIT 2 1-2 Armv~lnts*No. 3z 3 n. 162

.Iu-1

DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT to restore The purpose of CTS 3.6.1.6 is to ensure action is taken expeditiously change is acceptable containment structural integrity if it is not within limits. This importance to take action because a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is representative of the confirmed are unlikely expeditiously. Containment structural integrity problems once The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time frame is to be corrected in as short a period of time as 1 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

to place the unit consistent with the ITS 3.0.3 requirement to make preparations more restrictive outside the MODE of Applicability. This change is considered because the completion time for an action in the CTS is reduced.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES CTS 1.6 states, LA. 1 (Type 2 - Removing Descriptionsof System Operation)

All equipment hatches are "CONTAINMENT INTEGRITY shall exist when:... 1.6.2 This changes closed and sealed." 3.6.1 states, "Containment shall be OPERABLE." V-4 1 to the Bases.

the CTS by moving the reference to the equipment hatch being closed by DOC L.1.

The change deleting the phrase "and sealed" is addressed operation, from the The removal of these details, which are related to system of information is not Technical Specifications is acceptable because this type to provide adequate necessary to be included in the Technical Specifications still retains the requirement to perform protection of public health and safety. The ITS with the required visual inspections and leakage rate testing in accordance with 10 CFR 50 Appendix Containment Leakage Rate Testing Program in accordance is closed. Also, J, Part B, which would provide verification that the equipment hatch will be adequately this change is acceptable because the removed information are controlled by the Technical controlled in the ITS Bases. Changes to the Bases program provides for the Specification Bases Control Program in Chapter 5. This controlled. This change is evaluation of changes to ensure the Bases are properly because information relating designated as a less restrictive removal of detail change Specifications.

to system operation is being removed from the Technical 1.6 states, PA LA.2 (Type 2 - Removing Descriptionsof System Operation) CTS penetrations required 3 C.1--ý exist when:... 1.6.1 All "CONTAINMENT INTEGRITY shall by an 3V -1 are either: a. Capable of being closed to be closed during accident conditions e or b. Closed by manual OPERABLE containment automatic isolation valve system, secured in their closed valves, blind flanges, or deactivated automatic valves control as permitted by positions, except for valves that are open under administrative mechanism associated with Specification 3.6.3.1." CTS 1.6.5 states, "The sealing Page 3 Revision 14 North Anna Units 1 and 2

DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT This changes the each penetration (e.g. welds, bellows, or 0-rings) is OPERABLE."

Bases. AuI CTS by moving the 1.6.1 and 1.6.5 portions of the definition to the 3.6.1 from the 3-0-3 The removal of these details, which are related to system operation, information is not ý,14 this type of Technical Specifications is acceptable because adequate necessary to be included in the Technical Specifications to provide requirement for the protection of public health and safety. The ITS still retains the aspects of containment to be OPERABLE and the relocated material describes removed information OPERABILITY. Also, this change is acceptable because the Bases are controlled will be adequately controlled in the ITS Bases. Changes to the

5. This program by the Technical Specification Bases Control Program in Chapter properly controlled.

provides for the evaluation of changes to ensure the Bases are of detail change because This change is designated as a less restrictive removal the Technical information relating to system operation is being removed from Specifications.

LESS RESTRICTIVE CHANGES "CONTAINMENT L. I (Category I - Relaxation of LCO Requirements) CTS 1.6 states, are closed and sealed."

INTEGRITY shall exist when:... 1.6.2 All equipment hatches This changes 3.6.3 states, "Each containment isolation valve shall be OPERABLE." *_J hatches. The the CTS by not including an explicit reference to sealing the equipment hatch to the Bases is change associated with moving the reference to the equipment addressed by DOC LA. 1. R equipment hatches can The purpose of CTS 1.6.2 is to help provide assurance that the the LCO perform their safety function. This change is acceptable because components are requirements continue to ensure that the structures, systems, and The Containment maintained consistent with the safety analyses and licensing basis.

accordance with 10 Leakage Rate Testing Program requires testing be performed in valves, including the CFR 50 Appendix J, Part B, requiring the containment isolation of sealing the equipment hatch, is OPERABLE, but there is no specific mention because less stringent equipment hatches. This change is designated as less restrictive in the CTS.

LCO requirements are being applied in the ITS than were applied Page 4 Revision 14 North Anna Units 1 and 2

IT5 3,6bZ 9 Al 3.6.1-1

!Ap5-0e- z p rnimflNS ICoritirmjed 4-22-94

a. Capable of being ciowe by an OPERABLE crxmanmer ammra=i mosm a lo PbI/

sy*mer. or ammr i'roI sconfMan by .6..1

b. Closed by nwuai vafre. blind lanpe, or deacated amomtirru. vatm-j secured' intheir clos poskios eolS for S vabks that ame open 13110S SW~5acogr&

1.6. (AN 9C rK tutas ýarf Kte J's 3AuI

.<S I .". Each air bwlCa OPIERABLE pwwMer So SpecMicatimn3313

,*swLowimsawnvwtthor-hwwbg. 9

~~Ps I I? WT 2 -12i.? i ft CONTROLLED "1.7 seaklM FLO LEAKAGE shin be Vhal sa" wawe flow spie ID fte Mawr Cool=m v N 1.6 CORE ALTERATION shin be the n wmover m rrs'n ori cc WWy ewrgonemwa v Pi rua~o pressur vessel with Pus vw*aI huid mnwvvsd and kuel inPie vwi . aispersion of CORE ALTERATION "tl not precbk0e wri*ttn at nvvnnwm of a wvconetw io a saet

'e 1.9 The CORE OPERATINLG UWfTS REPORT Isthe unk-opecft doomewl VWa povdg i17r$

com opwraftku bT*s forthe c~mm opeluling relod cycle. Thes cyd4.spe~ir cm Oeat limbe shOa be Marnaemmd 1w eaci reoe qcfl InMidaI with Speffmtdw 6..1.7 i "opratin wfttn these opehftVu lib Isor memduse ins wwmwwja qmdbcawm DQSF FOtJIVALENT t1213 1.10 The DOSE EOL"VALBEJT -131 shelbe Ptt onnosrtu1on 041131 nim~wciriesgw wtci alone would pro~xe the so fm thyrold doese as the %awtiy an oc 56"o of 1-131, 1 132.15-133. 1-134 and 1-135 &=May prnsei The thyroid dose oiwwfsbn Is~om used for V*

cahkjuatn "hI be tmse hood in Table III04 TID,14344. T4caidmbion of Dlwma. Factor lor PvWr ami 1es1 Resmo Skas'

!-AvE-R Ar( flNTE(sRATx:ON FNFRCay I1.11 E sll be ft averae (we~ indb' p c pcrwdcr So fte conce mtimof @ e~sc rodiorucl inthe re aaw cookm VtP this ofm*l) a 04sm of fte sun of3 atverape boa anid qwnv orerpes per diairmqpaion (inthY) tor batope. other Van lodus. with hen bme Vmreaerth' s a bm~k 9%

15 rw'ss, 4 he tll ~nlo~e ~1hyin"P woolwI.

i NORTH ANNA.-UNIT 1 1-.2 Anw Mm nwu No.46,41'34, 181 p~ ct, c 20ý (4t, Iq

4-29 (-(

PAT-3bm if- 4 rabJmflPJ tComin,,.4qA A MEmbirnONS (Co fi5,0;_f -I

a. Capable 01 being closed by anOPE 3LE~raln"Wnh autnomatic isolation %.

system.*or

b. Closed by manual valves, blind flanges, or deactivaed autorrtic valves seac intheir closed posiems, except for yam 18that are open under admninistrative control as permitted by Specdaa~n3 LLIý 1.6.3 Each air lock is OPERABLE pumueua to Specftcation 3.6.12.3 1.6.4 The contairilnett leakage rates are wthinthei &T*s of Spcicitio3.6.1.2 a-W ~ 2 I 1.6.5 Theselt~iii i II~aipn~tneg ~s oriOnrgs/

0ew is OPERABLE. <('~r$ .,1 1.7 CONTROLLED LEAKAGE shagl be that aseal w~afar tiow s~i to the reacW coiaug i AT,3.I.Z 1.9F COREP-ALTERTOIMl etenvmr rnakitd ia rnrwt reactor pressur vesse with the vesse I Ma remo~ved and tuel in the vesseL lsupesion of CORE ALTERATION shall nlot precb~t clentAbn of fwovemnein tOf & on;=Wn Woa Wa%

conservative position.

tC)RF OPFRATINtM LIMITS REPQRT Sze 1.9 The CORE OPERATING UMITS REPORT Is the wu-*eWucf *iuwmn tha povides core op rating krnbt to the Mmmur "pruail reload cycle. The"e cycI.-pe~ccio re operofti birnits shall be determrrued tor each rebidd cyle,in accrdance with Spec:11tation 6.9.1.7 PluM operation within thes ope rating limits is add~ressed in hidiividual apeciticationig.

DQRF FOIJIVAI FN4T 1-121 1.10 The DOSE E-OUIVALENJTI-131 shall belthat ncentration at 1131 (miboacriez~gram) which alonme would pi ceJPue siaum thyroid dose as Pue Wanamy and- 6otPic, rriztze at 1-131.,1 132. 1-133. 1-134 arid 1-135 &aually preserL The thyroid doese conergion taaiors used tar Vthi calmI laion "lIa be 0ts limed hi Tabie III of TID-1484. "CaklaMtton of Distance Faotar tor Power and Test Rea=o SksV.

1.AVFRAtGF fllSIMTFCATION ENF-RMY 1.11 E shag be fth avrage (weigtied In proportbon to the sosrcerulion of each radlotudid I

m the re a~or oar3 t uthtirme 0sarping)0 uano teaeaebtaai ain

~.energies per disfvuegruon (in kieV) for motopes. other than iolinies, with ha l ivis grsmer than 15 rniries, making up Wt leaa 9M%at the total non-iodines adivfty in the colat.cI "I NORTH ANNA - UNIT 2 1-2 Anandiniet~ No. 2:3.3c, 162 04 2~~47..

V2e 1,q

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.1 Containment DOC A.8 (CTS 1.0)

(3.6.1-3) Bases JFD 2 CTS 1.6.5 STS B3.6.1 Bases - BACKGROUND ITS B3.6.1 Bases - BACKGROUND 1.6 is NRC RAI: CTS 1.6 defines CONTAINMENT INTEGRITY. A markup of CTS A.8 provided in the CTS markup of CTS 1.0, but not in the markup of CTS 3.6. DOC INTEGRITY is deleted from the (CTS 1.0) states that the definition of CONTAINMENT CTS/ITS. DOC A.8 is incorrect. CTS 1.6.5 states that 'The sealing mechanism STS associated with each penetration (e.g., welds, bellows, or O-rings) is OPERABLE."

defining the leaktight barrier.

B3.6.1.1 Bases - BACKGROUND has a similar statement made to ITS B3.6.1.1 Bases - BACKGROUND deletes this statement based on changes no changes to the ISTS (Bases JFD 2). Since CTS 1.6.5 is contained in the CTS and B3.6.1.1 the ISTS were made with regards to this item, it needs to be included in ITS Revise ITS B3.6.1.1 Bases - BACKGROUND to Bases - BACKGROUND. Comment:

and justification for its deletion based include CTS 1.6.5 or provide additional discussion on system design, operational constraints, or current licensing basis.

1.6.5 is Response: The Company will take the action proposed in the Comment. CTS and justified by marked as part of ITS 3.6.3. Requirements for CTS 1.6.5 are deleted sections the DOC L.14. CTS Pages in Section 1.0 are marked to describe to which ITS respective requirements are being moved.

Additional Response: Based on verbal comments from the NRC, the previous being response is modified. CTS 1.6.5 is relocated to the ITS 3.6.1 Bases instead of to document the deleted. The ITS 3.6.1 CTS markup is revised and DOC LA.2 is added is revised and ITS relocation of CTS 1.6.5 to the 3.6.1 Bases. The ITS 3.6.3 CTS markup 3.6.3 DOC L.14, which deleted CTS 1.6.5, is eliminated.

Containment B 3.6.1 BASES BACKGROUND b. Each air lock is OPERABLE, except as provided in (continued) LCO 3.6.2, "Containment Air Locks"; 3.6.1-3 R14

c. All equipment hatches are closed; and

d. The sealing mechanism associated with each penetration (e.g. welds, bellows, or O-rings) is OPERABLE.

APPLICABLE The safety design basis for the containment is that the of SAFETY ANALYSES containment must withstand the pressures and temperatures the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a challenge to containment OPERABILITY from high pressures and temperatures (REA) are a LOCA, I3.6.1-4 a steam line break, and a rod ejection accident R1 (Ref. 2). In addition, release of significant fission a product radioactivity within containment can occur from LOCA or REA. In the DBA analyses, it is assumed that the containment is OPERABLE such that, for the DBAs involving release of fission product radioactivity, release to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.1% of containment air weight per day doses (Ref. 3). This leakage rate, used to evaluate offsite resulting from accidents, is defined in 10 CFR 50, Appendix J, Option B (Ref. 1), as La: the maximum allowable containment leakage rate at the calculated peak containment internal pressure (Pa) resulting from the limiting design basis LOCA. The allowable leakage rate represented by La forms the basis for the acceptance criteria imposed on all containment leakage rate testing. La is assumed to be 0.1% of containment air weight per day in the safety analyses at Pa = 44.1 psig (Ref. 3).

Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of 10 CFR 50.36(c) (2) (ii) .

LCO Containment OPERABILITY is maintained by limiting leakage to

1.0 La, except prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test. At this time the applicable leakage limits must be met.

(continued)

B 3.6.1-2 Rev 14 (Draft 1), 01/10/02 North Anna Units 1 and 2

Containment BEs3.6.1 BASES

2. closed by manual valves, blind secured flanges, ortheir BACKGROUND in (continued) de-activated automatic valvesprovided in closed positions, except as LCO 3.6.3, "Containment Isolation Valves":

b. Each air lock is OPERABLE. exce t as provided-in LCO 3.6.2. "Containment Air Locks":

c. All equipment hatches are closed- and Aftl

d. The GrgaffU3e sealing mechanism associated with neLrtio isOPER.ABVL. e _as prq Jý is that the APPLICABLE The safety design basis for the containment and temperatures of SAFETY ANALYSES containment must withstand the pressures the design leakage rate.

the limiting DBA without exceeding a challenge to OBAs that result inpressures containment The DfromAhih and temperatures are a (esOo I om steam line

)J Ref.a 2).

LC9 break, and n addition, rele a r6o ejection ota accen within containment significant fission product radioactivity the DBA analyses, it is can occur from a LOCA or REA. In such that, for the assumed that the containment is OPERABLE product radioactivity.

DBAs involving release of fission by the rate of release to the environment is controlled was designed with an containment leakage. The ;ont*?i*nt off containment air weight allowable leakage rate of used to evaluate per day (Ref. 3). This leakage rate. is defined in offsite doses resulting from accidents, CFR 50. A ndix (Ref. 1), as L,: the maximum peak S10 owa e containment leakage rate at the calculated containme internal pressure (P ) resulting from the by L.

limitin D The allowable leakage rate representedon all imposed a /OCA forms t asis for the acceptance criteria L, is assumed t Je-n con ain nt leakage rate testing. alyses at P, = "4.4] psig be 0.IUper day in the safe-y" r3).eqcog%

-* . oo-*r' (Re.

are a requirtment for Satisfactory leakage rate test results OPERABILITY.

the establishment of containment (continued)

B 3.6-12 Rev 1, 04/07/95 WOG STS Pev. 1k

IT -5 3, 6,(

TT5 - ,q'iVbjC .l 4-22-94 1.0 Drr-,=ý ý V ... =czý 1.6.2 Rk3 3.b.2-z 1.6U 1.6A The g=nairvwuW leakage r~ats Wre wkttdl fte ks Of Spe~ooliai 3.L.1.2 anid 1.6s.5 (; seao1%""i rig 1.7 CONTROLLED LEAKAGE SWie be VWi502 WeSW falorw u toe the MreWo Cooar RA1 3,-1 rCQRF Ml TERATION 1.8 CORE ALTERATION SW be fte movetvert or nu*okdn of arm co~gam W06 the i I roamor pressurs vena~l with the vases I had nren~vd ari Wuein1w wesal. wspernso 01 CORE ALTERATION OWai not prockJde rWtbn oflWmwflWU m ot a cooponwwt jo a w%

r-DPF OPFP.ATRM [LIM~ REPORT 1.9 The CORE OPERATING WITfS REPORT Is Vie wi-up clac omew ifm pmovdas core optrawV~ bint for tie cfoxrtr "prtns rokad cycle. Those c yre operaticm lirrft stie be CWtrrnred or eac relcmd cyd hi a~drcan wilt Spe~ctin6.17Pui rop.bin wiw~thenVse opeattV~ lrim bis~eae inhkvbiWJ upemuiobwm

!DORF FOI JIVAI FNT I1-12 The DOSE EOUIVALBJT 1-131 shaDbe tiulrwomrallonf 1.131 (Noowji.*rm Ke=

1.10 whcbrw~ WOUV woui UNUiam~~o~

th Vo C do" the .as &W b ariat w= *xof t 1ý-l .13, 132.1-133.,1- 134 a-rid 1-135 aCUaly PVesaf The thyrod 00" CWrWf~bn t"MMr Used tor ths icaa~icuW~n shaD be Vioe toed kn 1albb PlIot TID-14W4. Ctlcolslon df Dina=*~ Factors tor Powe~r arid Text jf.AVIFFRAG DIINTE-GAT)ON FNERtlY 11.11 ?Vstie be tie average twe*gtod hInppronloplnictie c i=rMrvalb a rdr sof in the re &=x cookaft at the Umi of wrpig) ot Vw sma oftVsaverage bew arid gammaa oriurpws per dilrWnVatlon (in M.V) llo b~owpes ottu tan'" with hag boss gr~amerVtar

&w, i

NORTH ANNA.- UNIT' I 1 -2 Al Wiwrus No..34,487 34 181 Pa c 50

2T75 31b,1 As~ 3,6,11, 1.0 DEFINMONS (rtie)4-22-94 -L 3. 6.- 1

a. being closed by an )PE comaihnnMr automnatic -aithon va-lve- 'dJ i.n their closed posior. a PI tor valves that are ope7rnoer aarnminst couirl as permutned b S~tciation 3.6.3.1. /I 1.6.2 ipMih1C are cio 1.6.3 Each air lcx* as OPERABLE pursuas so SPeCVcaM 3.a.3aonT, 3.6 --Q 1.6.4 The containment leakage meis arev,1thinte aSpeclation3.6.1.2 aMd act 1.6.5 1 s each pen. 4;~. wokI, be~bw49~4rsS 1.7 CONTROU..D LEAKAGE shoe be VWa sealwater flow toj.thue reacor c~ooia AT3:b.

jol Lpump~ Seas. roauw CORF ALTERATION 1.8 CORE ALTERATION "aI be the nwvotentr or nunoitatlb of "rw =nponerg wow~ te reamor pressur vessel with the vesselI head rernov and fuel inthe vesset.suemna CORE AZTERATION shall not prockide conpf~tn ofla nIwuiwra Cg a confponru 10 a sale conservative pSlI FI5MM CORE OPFRA-nNa timITs RFPo~rT IT5 1.9 The CORE OPERATING UMrTS REPORT Is the unk-secifi dlocuarmr VW role core ope ruinvg imis frthe " irrena "p r&WV rloamd Cycle. These cycle-mmecific cmr operaigm d,o brnfts "lafbe determined tor each re~ad Cycle inaccrclarce with Speclkalin 6.9.1.7 P11M ope ratin within thes operalarag hnftisuaddressd inffx*duvja specificaboe5.

nosF- EQU1VAI FtT l1-12) 1.10 The DOSE EOUIVALEIT 1-131 shall be tha conosrurallon oft-1131 (nuacr~aries1;ram) which akne woui prO~Jcs sarra thyrid MSehec~aartky andI 'Wroicnnixr90e t111131.

132. 1-133, I.-13 and 1-13S scusay present. The t1hyroid dose conwersln tacoor used tar ts cak:;iation "ha be those lied hinable III at TID-148Ql.CAlbjftmconatDlmukre Famtora w Power and lest Rea= SkWe.

?-AVFR Ac;F DitwaiNTgRAT1 :NERgtY I.i., sham be the average (weigt~ed in propoution to the concenshalln of each radiorwcfide tin thie reactor woolarl at the tvne of sarrpling) 01 the sumn of the average beta and 9affna I.erervies per disimegralfion (in M@V) fm isotopes, other than iodanes, with hall Wes greaer tha

~¶5marites lsat95%

rnkkigi,~at1 te toal on-idin a~ivnyh the Coolant.

NORTH ANNA.- UNIT 2 1-2 Amnmwa~wNo..3: s.331 62 S,,ý 5 F-0 , .1.

DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT The purpose of CTS 3.6.1.6 is to ensure action is taken expeditiously to restore containment structural integrity if it is not within limits. This change is acceptable action because a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is representative of the importance to take unlikely expeditiously. Containment structural integrity problems once confirmed are 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time frame is to be corrected in as short a period of time as 1 or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The consistent with the ITS 3.0.3 requirement to make preparations to place the unit outside the MODE of Applicability. This change is considered more restrictive because the completion time for an action in the CTS is reduced.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES states, LA. 1 (Type 2 - Removing Descriptionsof System Operation) CTS 1.6 1.6.2 All equipment hatches are "CONTAINMENT INTEGRITY shall exist when:...

changes closed and sealed." 3.6.1 states, "Containment shall be OPERABLE." This Bases.

the CTS by moving the reference to the equipment hatch being closed to the The change deleting the phrase "and sealed" is addressed by DOC L.1. 3 ,j-L The removal of these details, which are related to system operation, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate to perform protection of public health and safety. The ITS still retains the requirement required visual inspections and leakage rate testing in accordance with the 50 Appendix Containment Leakage Rate Testing Program in accordance with 10 CFR Also, J, Part B, which would provide verification that the equipment hatch is closed.

this change is acceptable because the removed information will be adequately Technical controlled in the ITS Bases. Changes to the Bases are controlled by the provides for the Specification Bases Control Program in Chapter 5. This program change is evaluation of changes to ensure the Bases are properly controlled. This information relating designated as a less restrictive removal of detail change because to system operation is being removed from the Technical Specifications.

PA LA.2 (Type 2 - Removing Descriptionsof System Operation) CTS 1.6 states, 3 C.1-1)

All penetrations required "CONTAINMENT INTEGRITY shall exist when:... 1.6.1 3V-1 either: a. Capable of being closed by an to be closed during accident conditions are OPERABLE containment automatic isolation valve system, or b. Closed by manual e I' closed valves, blind flanges, or deactivated automatic valves secured in their as permitted by positions, except for valves that are open under administrative control with Specification 3.6.3.1." CTS 1.6.5 states, "The sealing mechanism associated Page 3 Revision 14 North Anna Units l and 2

DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT This changes the each penetration (e.g. welds, bellows, or O-rings) is OPERABLE."

X0AIt CTS by moving the 1.6.1 and 1.6.5 portions of the definition to the 3.6.1 Bases. 30I-1 from the 3.--3 The removal of these details, which are related to system operation, is not 014 because this type of information Technical Specifications is acceptable adequate necessary to be included in the Technical Specifications to provide for the protection of public health and safety. The ITS still retains the requirement aspects of containment to be OPERABLE and the relocated material describes information OPERABILITY. Also, this change is acceptable because the removed are controlled will be adequately controlled in the ITS Bases. Changes to the Bases

5. This program by the Technical Specification Bases Control Program in Chapter are properly controlled.

provides for the evaluation of changes to ensure the Bases because This change is designated as a less restrictive removal of detail change the Technical information relating to system operation is being removed from Specifications.

LESS RESTRICTIVE CHANGES "CONTAINMENT L. I (Category I - Relaxation of LCO Requirements) CTS 1.6 states, hatches are closed and sealed."

INTEGRITY shall exist when:... 1.6.2 All equipment This changes 3.6.3 states, "Each containment isolation valve shall be OPERABLE."

hatches. The j *I the CTS by not including an explicit reference to sealing the equipment to the Bases is .3..

change associated with moving the reference to the equipment hatch addressed by DOC LA. 1.

equipment hatches can The purpose of CTS 1.6.2 is to help provide assurance that the the LCO perform their safety function. This change is acceptable because systems, and components are requirements continue to ensure that the structures, The Containment maintained consistent with the safety analyses and licensing basis.

in accordance with 10 Leakage Rate Testing Program requires testing be performed valves, including the CFR 50 Appendix J, Part B, requiring the containment isolation of sealing the equipment hatch, is OPERABLE, but there is no specific mention because less stringent equipment hatches. This change is designated as less restrictive applied in the CTS.

LCO requirements are being applied in the ITS than were Page 4 Revision 14 North Anna Units 1 and 2

1-rs5 ,.

AAI.a-h 4-22-94 f,~r AT~ I TT5 A 0%

nJmONS (Conhirmjed ncr'Nmcws (Continued)

Capable of being osdby an OPERABLE wrUakiMMn autornatc isolaln valve s9 3.b. 3 1 sysPem. or R 3.3 {b.. Closed by mamiua valves. blind Wipes, or deactirmed auorwuzc valvft ecure in their WN4s Of' valvesepVW~~a aws o"e

'93b3A('1O moe I.

1.e.2 Ja po@e.e hace are clse and seld 1.9.3 a0 OPEATL puria mwwg to QkGbc p4mon 3. '

1.6A u ~e~

1.6. ~ 5~da~d wi ~ S 34Ws.2 an@Iw m -rng) )

1.7 CONTROLLED LEAKAGE "labe tha seal watrtow suoe a o1w f reator CDOM b.3:

i3.

purrp) "sea.

1.3 CORE ALTERATION shl be the fllvwmerlwEOffw*zAW3Uol wWcy~iooner wkltt rsaw= ressure vessel with the veem head fsnvvsd WO fue in 1w vessel. ajapension Wi CORE ALTERATION OWei not preckutIt cimpebo mvemeru cmwonr oa sormwlan%

wnservam e Psiton Q-QRF OPERATMN LIUMT REPORT

ý,e 1.9 The CORE OPEPLAT0NG LIMITS REPORT Iste 1wuni-spee doajrem tha pmvie wre operalk ing toe f the uvrn" "pratingrelod cycie. The"e Wyo-pai. icore operating limb shall be cemerrurmd lo eac Nbaod Wcyle in,aCWzl~n wllh Specifiaton 6.9.1.7 Plar's "apration wifttn thes opeutrig WeTda Imedchs -c'in inKvbjaJ speoftabaow "Mar. &W1ALXCM.Qmj-="

1.10 The DOSE EOUIVALENT 1.131 shial be OWt awnoruvulon of 1,-131 1nm~omaiewpgano wtK1h alone would puo~.i the sm "wVhrow do"se 51w Wantky an W o lc rib~ss of 1-131.,1 132. 1-133, 1-134 and V1135 Siuialy, preswLs The tVyrcidcb~ewworabrn twors used for this c~alwIatln stull be 1ess W~ed in lable II1 of TID-1d4W. TAm~ticn of Dkstance Faoiux tor PC~e and leat ReW 8Ws.'

F-AER CE 1SIWTEr4R A-TX)N EMERGY 1.11 "1habe "warverage tw*VtWludin piopwlon t 1we wor-anwuat onf eac redt41~d inm rhe enw wobia ad the Wmn of san*I) of 1w sum of Me aermage bets and wmm energies per disintegration (in 11eV) be imcomoe, other than Iordi wati haMll~espremo Ian 1$ rrw".es mel~ki up0 atlw 95% of the WWI nwon.wI wvky in the voolwL i

NORTH ANNA - UNIT I 1-2 AvvrwndnwrusPb.3,4.,.346 9181 P,6

-ITS p z3, 1.0 DEFINITONS (COMtiUed 4-922-94 RA 13.b.l-l (a.

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CORE ALTERATION Shall rot pfSmbjds cornilelort of tixy. rme of a cornporomt to a &ate conservalsve posaton.

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.envergies per disirsegratbon (in M*V) toe motopes, other than lodines with haf bees greater than 15 rnwines, mnakkVgLup Wt Weas 9M%at the total nmn-kdi activiy in the coolaMt NORTH ANNA - UNIT 2 1-2 NOR~h NNA-UNT2 1- No3.4.2O,.

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DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES misinterpreting the requirements of the Surveillance Requirement while maintaining F#

as less restrictive 3.C.2 I the assumptions of the accident analysis. This change is designated applied in the ITS than I Requirements are being because less stringent Surveillance were applied in the CTS. RA4 L.14 Not used.

L.15 (Category 3 - Relaxation of Completion Time) CTS 3.6.3.1 states that with one or in more isolation valves inoperable, maintain at least one isolation valve OPERABLE each affected penetration and restore the inoperable valve to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.6.3, ACTION D, states that with purge valve penetration 3.(.*3-2 leakage not within limit, restore leakage within limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes Rja the CTS by relaxing the Completion Time for inoperable purge valve penetrations from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The purpose of CTS 3.6.3.1 is to ensure that containment penetration leakage is is within the assumed limit. This change is acceptable because the Completion Time consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed is Completion Time. Allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to repair a leaking purge valve penetration appropriate because the valves are required to be closed and a gross breach of containment would fall under the requirement of LCO 3.6.1, "Containment." If the leakage through the purge valve penetration exceeds the LCO 3.6.1, "Containment,"

limit, then the ACTIONS of that Specification must be followed. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L.16 (Category4 -Relaxation of RequiredAction) CTS 4.6.1.1.a requires verification that Z all non-automatic containment isolation valves that are required to be closed are closed every 31 days. If a non-automatic valve that is supposed to be closed is found 3. .

primary 3.6.3-6 open, CTS 3.6.1.1 Action applies. That Action states, "Without lel#

within one CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY hour or be in at least Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Cold Shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." ITS 3.6.3 ACTIONS do not differentiate between automatic and non-automatic valves and allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate the affected flow path. ITS 3.6.3 allows continued operation with the inoperable containment isolation valve, but if the Required Actions and associated Completion Times are not met, a shutdown to MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is required. In addition, ITS 3.6.3 ACTIONS Notes 2, 3 and 4 allow separate condition entry for each penetration flow path, require entry into the applicable Conditions and and Required Actions for systems made inoperable by containment isolation valves, 3.6.1, require entry into the applicable Conditions and Required Actions for LCO the "Containment," when leakage for a penetration flow path results in exceeding Revision 14 Revision 14 North Anna Units 1 and 2 Page 16

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.2 Containment Air Locks STS SR 3.6.2.2 (3.6.2-9) ITS SR 3.6.2.2 and Associated Bases in the air lock will open at a NRC RAI: STS SR 3.6.2.2 requires verifying only one door SR 3.6.2.2 from 6 months to time at a 6-month interval. The interval is modified in ITS Rev. 2; however, the Bases 24 months. This modification is in accordance with TSTF-17 Comment: Revise the ITS Bases changes are not in accordance with TSTF-17 Rev. 2.

to be in accordance with TSTF-1 7 Rev. 2 or justify the deviations.

The sentence, Response: The Company will take the action proposed in the Comment.

is justified based on generic operating "The 24 month Frequency for the interlock 9 is added and the TSTF-17 experience." is added to the SR 3.6.2.2 Bases. Also, JFD insert is modified to justify how the TSTF was addressed.

the NRC, the previous Additional Response: Based on verbal comments from to reflect Revision 2 of response has been modified. The TSTF-17 insert is revised TSTF-1 7.

Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.2 (continued)

REQUIREMENTS OPERABILITY if the Surveillance were performed with the RAI reactor at power. Operating experience has shown these 3.6.2-9 at components usually pass the Surveillance when performedbased RI, R14 the 24 month Frequency. The 24 month Frequency is also on engineering judgment and is considered adequate givenair that the interlock is not challenged during use of the lock.

REFERENCES 1. 10 CFR 50, Appendix J, Option B.

2. UFSAR, Section 6.2.

3. UFSAR, Chapter 15.

B 3.6.2-8 Rev 14 (Draft 1), 01/10/02 North Anna Units 1 and 2

ITS 3.6.2, CONTAINMENT AIR LOCKS INSERT on-he need to perform this All every 24 months. The 24 month Frequency is based outage, and the potential for lossoj 74.-2 during a Surveillance under the conditions that apply with(* . .

ofi BW nl containment OPERABILITY if the Surveillance were performed that these components usually pass the retor at power. Operating experience has shown at the 24 month Frequency.

the Surveillance when performed Insert to Page B 3.6-27 Revision 14 North Anna Units 1 and 2

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.3 Containment Isolation Valves DOC A.1 (3.6.3-2) JFD 3 Bases JFD 2 CTS 4.6.1.1 .d Bases STS 3.6.3, ACTIONS A, B, D, and E, SR 3.6.3.7 and Associated ITS 3.6.3, ACTIONS A, and B and Associated Bases the butterfly isolation valves NRC RAI: CTS 4.6.1.1 .d requires specific leak rate tests for ejector lines. The CTS markup of in the containment purge and the containment vacuum for changes associated with CTS 4.6.1.1 .d in CTS 3.6 refers the reviewer to ITS 5.5.15 out of the this specification this specification. The CTS markup for ITS 5.5.15 relocates by DOC change is justified ITS to the Containment Leakage Rate Testing Program. This specifics of not contain the A.26 (CTS 6.0). This change is incorrect. ITS 5.5.15 does which is outside the program, this specification; the specifics are contained in the body of would be a Less Restrictive (LA) change.

of TS. Thus the change, if acceptable, specification needs to be retained in the North However, the staff concludes that this North Anna Unit 1 and Unit 2 TS Anna ITS. Amendments 196 and 177 to the J, Option B.

10 CFR 50 Appendix respectively, dated February 9, 1996, implemented based Rate Testing Program The amendment change approved a Containment Leakage include this and did not on 10 CFR 50 Appendix J, Option B that was outside of the CTS, Since this specification specification in that program, but retained it in CTS 4.6.1.1 .d.

requirements not contained in 10 CFR 50 Appendix J, Option contained specific testing STS does contain an SR B, it should be retained in the ITS as an SR in ITS 3.6.3. The relocate the purge valve on purge valve leakage. TSTF 52 Rev. 3 did not remove or retained because the testing leakage SR (STS SR 3.6.3.7). In fact, STS SR 3.6.3.7 was of 10 CFR 50 Appendix J. This STS requirements went beyond the test requirements seals. It would seem that SR deals with leakage testing of purge valves with resilient seals, but this is not stated CTS 4.6.1.1 .d was retained because the valves had resilient JFDs. If these valves do in CTS 4.6.1.1 .d, the Bases for ITS 3.6.3, or in the DOCs and the ITS. Even if they do have resilient seals, then CTS 4.6.1.1 .d needs to be retained in because of the special not have resilient seals, the specification needs to be retained 10 CFR 50 Appendix J. Thus, testing requirements which go beyond the requirements of testing STS SR 3.6.3.7 needs to be used or modified to reflect plant-specific ACTION is being added to the ITS, an appropriate requirements. Since this STS SR would be STS 3.6.3 needs to be provided for when the SR is not met. This ACTION 5 and any plant-specific requirements.

ACTION D or E as modified by TSTF-207 Rev. ITS 3.6.3 ACTION. In addition, This may result in modifications/changes to CTS 3.6.1.1 Rev. 5. Comment:

Conditions A and B will need to be revised to conform to TSTF-207, the appropriate Revise the CTS/ITS markup to retain CTS 4.6.1.1 .d and provide all the changes associated with this SR retention.

discussions and justifications for in the Comment, with certain Response: The Company will take the action proposed modifications.

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems as modified and The CTS 4.6.1.1 .d markup is modified, adopting the requirement as modified and justified by DOC A.12, A.13, and LA.4, adopting ISTS SR 3.6.3.7, justified by JFD 10.

LA.12 is added to reflect ITS 5.0 markups are modified, DOC A.26 is deleted, and DOC these changes.

met will be Condition A or

The ITS Condition to be entered when ITS SR 3.6.3.7 is not are inoperable. ISTS B, depending on whether one or two valves in a penetration because leakage in the purge ACTIONS D and E for the purge valves are not necessary of other valves will be treated in the same manner as leakage or inoperability basis.

containment isolation valves, consistent with the current licensing A, B and D are not The shield building bypass related portions of ISTS ACTIONS adopted because NAPS does not have a shield building.

D are not adopted

The purge valve related portions of ISTS ACTIONS A, B and purge valves are the same because the Required Actions and Completion Times for the as for other containment isolation valves.

ISTS ACTION E is not adopted because the Required Actions are the same as those E.2 Completion times are 24 for ISTS ACTION A, except the Required Action E.1 and SR 3.6.2.7 be performed once hours, and ISTS Required Action E.3 requires that ISTS closed to comply with Required Action per [921 days for the resilient seal purge valves E.1. ISTS SR 3.6.2.7 will not be performed at NAPS.

of ISTS 3.6.3 JFD 3 is modified to only address shield building bypass portions ACTIONS A, B and D.

of ISTS 3.6.3

JFD 7 is added to address not adopting the purge valve portions ACTIONS A, B and D, and ISTS 3.6.3 ACTION E.

because ISTS 3.6.3

TSTF-207 Rev 5 will be marked into the ISTS markup. However, "or more" in relation to ACTIONS D and E are not adopted, and the bracketed term package will not result in a isolation valves is not adopted, these changes to the ITS change to ITS 3.6.3.

JFD 8 addresses not adopting the term "or more."

the NRC, the portions of the Additional Response: Based on verbal comments from previous response marked with an asterisk are modified.

Rev. 5 are justified. The TSTF-207, Rev. 5, is adopted. Two deviations from TSTF-207, the phrase, "two change to Conditions A and B in TSTF-207, which replaces isolation valves" is not containment isolation valves" with "two or more containment only two valves in each of the adopted. As described in JFD 8, at North Anna, there are Reviewer's Note added by penetrations addressed by Conditions A and B. The STS to purge valve leakage which can TSTF-207, Rev. 5 states that Condition E is applicable

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems be measured separately for each purge valve, otherwise Condition D applies. Purge so valve leakage cannot be measured separately for each purge valve at North Anna, for Condition D, "Purge valve Condition D is adopted. However, the STS wording be leakage not within limit," is misleading since the leakage for a single valve cannot measured. Therefore, Condition D has been revised to state, "Purge valve penetration D Bases.

leakage not within limit." Corresponding changes are made to the Condition This change is consistent with the application of Condition D as described in the Reviewer's Note. DOC L.1 5 is added to describe the change.

and ITS JFD 7, which was inadvertently omitted from the previous response, is provided has been revised to reflect the addition of Condition D.

seals is The paragraph in the STS LCO Bases regarding purge valves with resilient added to the ITS Bases.

Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

-- - - - - - - - - - --------- NOTES ----------------

1. Penetration flow path(s) except for 36 inch purge and exhaust valves, and 18 inch containment vacuum breaking valve, 8 inch purge bypass valve, steam jet air ejector suction flow paths may be unisolated intermittently under administrative controls.

path.

2. Separate Condition entry is allowed for each penetration flow made

3. Enter applicable Conditions and Required Actions for systems inoperable by containment isolation valves.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1, in "Containment," when leakage for a penetration flow path results exceeding the overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A. --------- NOTE --------- A.1 penetration flow path AnlI 2nnlirVhlp to penetration flow paths by use of at least one closed and with two or more containment isolation de-activated automatic valves. valve, closed manual

valve, blind flange, or check valve with One or more flow through the valve secured.

penetration flow paths with one containment isolation valve AND RAI 3.6.3-2 inoperable for reasons other than R14 Condition D.

(conti nued) 3.6.3-1 Rev 14 (Draft 1), 01/10/02 North Anna Units 1 and 2

Containment Isolation Valves 3.6.3 ACTIONS REQUIRED ACTION COMPLETION TIME CONDITION B.1 Isolate the affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B. ---------NOTE------ penetration flow path Only applicable to by use of at least one RAI penetration flow paths closed and 3.6.3-2 R14 with two containment de-activated automatic isolation valves. valve, closed manual

valve, or blind flange.

One or more penetration flow paths 1RI3.6.3 R14 with two containment RAI 3.6.3-2 isolation valves R14 inoperable for reasons other than Condition D.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months C.1 Isolate the affected C. - -------- NOTE -------- penetration flow path Only applicable to by use of at least one penetration flow paths closed and with only one de-activated automatic containment isolation valve, closed manual valve and a closed valve, or blind system. flange.

One or more penetration flow paths with one containment isolation valve inoperable.

AND (continued) 3.6.3-3 Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2

Containment Isolation Valves 3.6.3 ACTIONS REQUIRED ACTION COMPLETION TIME CONDITION C.2 NOTES------ --------

C. (continued)

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

RAI D.1 Restore leakage within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months D. Purge valve limit. R14 penetration leakage not within limit.

-- I-3.6.3-2 E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months E. Required Action and R14 associated Completion AND Time not met.

Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 13.6.3-2 E.2 R14

_______________ J J ______________

3.6.3-4 Rev 14 (Draft 2), 01/31/02 North Anna Units I and 2

Containment Isolation Valves B 3.6.3 BASES APPLICABLE The containment isolation valves satisfy Criterion 3 of SAFETY ANALYSES 10 CFR 50.36(c)(2)(ii).

(continued)

LCO Containment isolation valves form a part of the containment boundary. The containment isolation valves' safety function is related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a DBA.

The automatic power operated isolation valves are required to have isolation times within limits and to actuate on an automatic isolation signal. The 36, 18, and 8 inch purge valves must be maintained locked, sealed, or otherwise secured closed. The valves covered by this LCO are listed along with their associated stroke times in the Technical Requirements Manual (Ref. 2).

The normally closed isolation valves are considered OPERABLE when manual valves are closed, automatic valves are de-activated and secured in their closed position, blind RAI flanges are in place, and closed systems are intact. These 3.3-13 passive isolation valves/devices are those listed in R1 Reference 2.

Purge valves with resilient seals must meet additional 3.3-2 leakage rate requirements. The other containment isolation R14 valve leakage rates are addressed by LCO 3.6.1, "Containment," as Type C testing.

This LCO provides assurance that the containment isolation valves and purge valves will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the containment boundary during accidents.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, the containment isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are addressed in LCO 3.9.4, "Containment Penetrations."

B 3.6.3-3 Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2

Containment Isolation Valves B 3.6.3 BASES ACTIONS The ACTIONS are modified by a Note allowing penetration flow paths, except for 36 inch purge and exhaust valve, 18 inch containment vacuum breaking valve, 8 inch purge bypass valve, and steam jet air ejector suction penetration flow paths, to be unisolated intermittently under administrative controls. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for containment isolation is indicated. Due to the fact that the 36 inch valves are not qualified for automatic closure from their open position under DBA conditions and that these and the other penetrations listed as excepted exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves may not be opened under administrative controls.

A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable containment isolation valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are further modified by a third Note, which ensures appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve.

In the event the leakage for a containment penetration flow path results in exceeding the overall containment leakage rate acceptance criteria, Note 4 directs entry into the applicable Conditions and Required Actions of LCO 3.6.1.

A.1 and A.2 In the event one containment isolation valve in one or more penetration flow paths is inoperable, except for purge valve 136.3-2 flow path leakage not within limit, the affected penetration R14 must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and (continued)

B 3.6.3-4 Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2

Containment Isolation Valves B 3.6.3 BASES ACTIONS A.1 and A.2 (continued) de-activated automatic containment isolation valve, a closed manual valve, a blind flange, or a check valve with flow through the valve secured. For a penetration flow pathdevice isolated in accordance with Required Action A.1, the used to isolate the penetration should be the closest available one to containment. Required Action A.1 mustis be completed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time the reasonable, considering the time required tosupportingisolate penetration and the relative importance of containment OPERABILITY during MODES 1, 2, 3, and 4.

For affected penetration flow paths that cannot be restored Time and to OPERABLE status within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion that have been isolated in accordance with Required be Action A.1, the affected penetration flow paths must is verified to be isolated on a periodic basis. This required necessary to ensure that containment penetrations capable of to be isolated following an accident and no longer being automatically isolated will be in the isolation does position should an event occur. This Required Action Rather, it not require any testing or device manipulation. that those involves verification, through a system walkdown, isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation as devices inside containment, the time period specifiedperformed "prior to entering MODE 4 from MODE 5 if not within the previous 92 days" is based on engineering of the judgment and is considered reasonable in view other inaccessibility of the isolation devices and administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

Condition A has been modified by a Note indicating flow that this paths Condition is only applicable to those penetration with two containment isolation valves. For penetration flow 13.6.3-2 paths with only one containment isolation valveactions. and a closed R14 system, Condition C provides the appropriate Required Action A.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation use areas and allows these devices to be verified closed by of (continued)

B 3.6.3-5 Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2

Containment Isolation Valves B 3.6.3 BASES ACTIONS A.1 and A.2 (continued) administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to verificationbe verified closed by use of administrative means. Allowing by administrative means is considered acceptable, since the is to function of locking, sealing, or securing components ensure that these devices are not inadvertently of repositioned. Therefore, the probability of tomisalignment be in the these devices once they have been verified proper position, is small.

B.1 With two containment isolation valves in one or more valve 3.6.3-2 flow paths inoperable, except for purge R14 penetration flow path leakage not within limit, the affected penetration of isolation must must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The method that cannot include the use of at least one isolation barrier be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manualconsistentvalve, and a Time is with blind flange. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion the ACTIONS of LCO 3.6.1. In the event the affected penetration is isolated in accordance with beRequired verified to be Action B.1, the affected penetration must A.2, which isolated on a periodic basis per Required Action is necessary remains in effect. This periodic verification to assure leak tightness of containment and that penetrations requiring isolation following 31an days accident are isolated. The Completion Time of once per for isolated is verifying each affected penetration flow path is are appropriate considering the fact that the the valves operated under administrative control and probability of their misalignment is low.

Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two 3.6.3-2 isolation valves. Condition A of this LCO R14 containment valve addresses the condition of one containment isolation inoperable in this type of penetration flow path.

B 3.6.3-6 Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2

Containment Isolation Valves B 3.6.3 BASES ACTIONS C.1 and C.2 (continued) the by administrative means is considered acceptable, since is to function of locking, sealing, or securing components ensure that these devices are not inadvertently of repositioned. Therefore, the probability of misalignment these valves, once they have been verified to be in the proper position, is small.

RAI 3.6.3-2 D.1

_____R14 With the purge valve penetration leakage rate (SR 3.6.3.4) not within limit, the assumptions of the safety analyses are not met. Therefore, the leakage must be restored to within limit. Restoration can be accomplished by isolating bythe use of penetration(s) that caused the limit to be exceeded manual one closed and de-activated automatic valve, closed valve, or blind flange. When a penetration is isolatedto the be leakage rate for the isolated penetration is assumed device. If the actual pathway leakage through the isolation penetration, two isolation devices are used to isolate the the leakage rate is assumed to be the lesser actual Time pathway hour Completion for leakage of the two devices. The 24 considering purge valve penetration leakage is acceptable the purge valves remain closed so that a gross breach of containment does not exist.

E.1 and E.2 If the Required Actions and associated Completion Times are not met, the unit must be brought to a MODE in which the LCO this status, the unit must be does not apply. To achieve to MODE 5 brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the an required unit conditions from full power conditions in orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.6.3.1 REQUIREMENTS This SR requires verification that each containment isolation manual valve and blind flange located outside and containment and not locked, sealed, or otherwise secured is closed.

required to be closed during accident conditions The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the containment (continued)

B. 3.6.3-8 Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2

Cont nt solation Valves (Atmospbe'ric.

ubatmos ric,. Ice Con~e ser. an Dua-3.6 CONTAI NMENT SYSTEMS 3.6.3 Containgent I.s1 .2n Valves r:(A:t-~nos~pheriZ

Suatmfo~sph ic, 1 LCO 3.6.3 Each containment isolation valve shall be OPERABLE.

3.'. I APPLICABILITY: MODES 1. 2. 3. and 4.

ACTIONS S... .... .............. ...-

--. U-.. ..

inch purge~valv* flow paths--may

1. Penetration flow path(s)fexcept for.*

administrative controls.

be unisolated intermittently under for each penetration flow path.

2. Separate Condition entry is allowed made and Required Actons for sys

3. Enter applicable Conditionsisolation valves.

inoperable by containment tions d Required.Ac4ions of*laLCO 3.6.1.

4. Enter applicable w Conea a 4 .e e. results in exceeding the Conalmet, . when rate acceptanceleakagea criteria.

3.b.A -1 i "Containment,"

overall containment ea age t.....................

REQUIRED ACTION COMPLETION TIME CONDITION Isolatethe affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A. ......... NOTE ......... A.1 penetration flow path Only applicable to by use of at least penetration flow paths one closed and with two containment de-activated

.i....... valv isolatio .. automatic valve, "closed manual valve, I7 blind flange. or One or more check valve with flow penetration flow paths through the valve A n

with one containment secured.

isolation valve for

.. ino erable (purge y e exce or i~~elo AND (continued) 3.6-B Rev 1. 04/07/95 WOG STS

iC, Containment isolation Valvestmosp~h "Qbamos~e-riC. ice Lo-tehserWa~n S.. .. u3

.6.3 ACTIONS REQUIRED ACTION -- COMPLETION C TIME CONDITION A.2 . NO ...

NEW~~A A. (continued) Isolation devices in

'high radiation areas

. e S4*to(JEU'fLL It__s re - .may be verified by T51 -17'L use of administrative

.J ý& v,'owt'i-h r k.L a~xare- ma* Jar

-/ckeAllseade L means.

Verify the affected Once per 31 days penetration flow path for isolation is isolated. devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment Isolate the affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B. ......... NOTE ......... B.1 Only applicable to penetration flow path by use of atandleast penetration flow paths one closed with tworcontainment isolatio valves. de-activated automatic valve, One or more closed manual valve.

or blind flange. TS-TF-ff (DIAt penetration flo -aths with two ontainnen isolation valves Inoperable excep f purge va e,or shi d buildi bypass leak not wi int

-Ii (continued)

Rev 1. 04/07/95 3.6-9 WOG STS

Valves WtmospOEric Containment C-uatmo Isolation rl .,, o serD, a-, Dual_

J.0-5 0

CT5 ACTIONS (continued)

REQUIRED ACTION COMPLETION TIME CONDITION hours 757f 3 C.1 Isolate the affected renetration flow path AA,- C.- Only -........

C NOTE .........

applicable to yuse of at least A-dfo.(, penetration flow paths one closed and with only one de- activated containment isolation automatic valve, valve and a closed closed manual valve.

system. or blind flange.

AMn One or more penetration flow paths with one containment C.

C'2 ( ........- NO~t Isolation -T0------

devices in isolation valve high radiation areas inoperable. may be verified by use of administrative means.

NEJW /orked3ade~v riI 39xfr&&

.SCC~-,SA 4

Lbe* tlf:AAJL Once per 3 days i'&~~

5ecLJ £Vtifl

~~ 4 l

-fJhf~law 1~$S

/eIl Verify the affected penetration flow path is isolated. .

-L. I - I

-.- I I"

.i Isolate the faffw path ted 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months E. one or more penetration penetration flo by ue of at east paths with o or one 91 ose and more contai nt de-adtiv d purge valv not automat

valve.

within pu e valve close manual valve.

leakage iits. or b nd flangz AND (citn Rev 1. 04/07/95 3.6-10 WOG STS

Containment isolation vavs(Atmosph~prc.

(JT$

0,P

)..37 PiL Ac4;b o0.

Rev 1. 04/07/95 3.6- 11 WOG STS

JUSTIFICATION FOR DEVIATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES (Atmospheric,

1. The headings for ISTS 3.6.3 include the parenthetical expression information is not included Subatmospheric, Ice Condenser, and Dual). This identifying to assist in identifying the in the NAPS ITS. This information is provided in the NUREG ITS conversion, but appropriate specification to be used as a model for a plant specific necessary editorial serves no purpose in a plant specific implementation. Therefore, changes were made.

information/value is provided.

2. The brackets are removed and the proper plant specific and other references to shield building bypass are le j ¶5-..

3. Conditions, Surveillance Requirements design.

bypass is not part of the NAPS not retained. Shield building

?O

4. Not used.

check valve used as a containment

5. ITS SR 3.6.3.6 requires each weight or spring loaded tested through one complete cycle isolation valve that can be tested during operation to be contains a similar of travel every 92 days. North Anna CTS Surveillance 4.6.3.1.1 not contain weight or spring requirement. ITS SR 3.6.3.6 is deleted as North Anna does that are testable during loaded check valves used as containment isolation valves operation. Therefore, this Surveillance does not apply.

that entry is required into the

6. ISTS 3.6.3 ACTIONS NOTE 4 is modified to clarify "Containment," when leakage applicable Conditions and Required Actions of LCO 3.6.1, leakage, results in exceeding for a penetration flow path, instead of when isolation valve The Containment is not the overall containment leakage rate acceptance criteria.

isolation valve in the affected flow inoperable if there is still an OPERABLE containment Action A.1 allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months path. This change is acceptable because ISTS 3.6.3 Required penetration flow paths with one to isolate the affected penetration flow with one or more A.1 and its associated containment isolation valve inoperable. If Required Action 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Completion Time is not met, the unit is required to be placed in MODE ISTS 3.6.1 which requires an and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This is consistent with within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or the unit is inoperable Containment be restored to OPERABLE status MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This is required to be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and also consistent with the current licensing basis.

and revised. 94.1

7. ISTS 3.6.3 ACTION E is not adopted. ISTS 3.6.3 ACTION D is adopted Condition E is states that The STS Reviewer's Note added by TSTF-207, Rev. 5 separately for each purge valve.

applicable to purge valve leakage which can be measured for each purge valve at North Anna, Purge valve leakage cannot be measured separately for Condition D, "Purge valve so Condition D is adopted. However, the STS wording for a single valve cannot be leakage not within limit," is misleading since the leakage "Purge valve penetration measured. Therefore, Condition D has been revised to state, made to the Condition D Bases.

leakage not within limit." Corresponding changes are Page 1 Revision 14 North Anna Units 1 and 2

JUSTIFICATION FOR DEVIATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES This change is consistent with the application of Condition D as described in the I. 2 I

Reviewer's Note. Subsequent requirements are numbered and lettered accordingly.

t

8. The bracketed term "or more," added to ISTS 3.6.3 Condition A Note, Condition B Note, and Condition B, is not adopted. At NAPS, only two valves in each penetration ?.3..

current licensing oI addressed by Conditions A and B are required. This consistent with the basis.

9. ISTS SR 3.6.3.1, SR 3.6.3.2, and SR 3.6.3.10 are not adopted. Purge valves are not /?A*

ýC3-4 opened in MODES 1, 2, 3 and 4, and do not automatically close. The CTS treat the purge valves in the same manner as other manually operated containment isolation valves. As stated in the ISTS SR 3.6.3.1, SR 3.6.3.2 and SR 3.6.3.10 Bases, the separate criteria applied to purge valves in the ISTS are related to use of the valves in MODES 1, 2, 3, and

4. Subsequent requirements are numbered and lettered accordingly.

10. The Frequency of 184 days and within 92 days after opening the valve in ISTS SR 3.6.3.7 is changed to, "Prior to entering MODE 4 from MODE 5 after containment vacuum has been broken." The NAPS containment is subatmospheric and testing the containment 3-Z purge valves with resilient seals while in MODE 1, 2, 3, or 4 is not performed for industrial safety reasons. The Frequency which is proposed will test the valves before entering the MODE of Applicability each time containment vacuum is broken and the valves can be tested safely. Maintenance history supports this Frequency, and the Frequency is consistent with the current licensing basis. Subsequent requirements are numbered and lettered accordingly.

and 22 Page 1 Revision 14 Units 1I and North Anna Units Page I Revision 14

(Atmos ic.

Containment IsolationValve uDual BASES (continued) of the containment LCO Containment isolation valves form a part valves' safety function boundary. The containment isolation of reactor coolant is related to minimizing the loss containment boundary during a inventory and esta lis ing the DBA. I-e ar ikrwts~se; 5() . 146u %.I a ves are required The au omatic ower operated isolation and to actuate on an to have isolation ti s within limit inch purge valves must isol tion ignal.

automatic -;Ati cig The s d ortnaVe Diocks inS 0

preven u openi ng . Blck urLvle(aoaut on an~tm s a. va yes covere y t is LCO are tims in theoB_

listed along with t eir associated stroke A__I __.-

2).

(Ref.

The normally closed isolation valves are considered OPERABLE D automatic valves are when manual valves are closed, position, blind their closed de-activated and secured in are intact. These flanges are in place. and closed systemsare those listed in passive isolation valves/devices Reference -RkF.

Purge valve ith resilient seals a cOna te c 2ntn S must meet additiona l *age isolation valve leakage requirements. The otherLCOcontainment 3.6.1. "Containment.- as Type C rates are addressed by testing.

isolation This LCO provides assurance that the containment their designed safety valves and purge valves will perform reactor coolant inventory functions to minimize the loss of during accidents.

and establish the containment boundary a release of APPLICABILITY In MODES 1. 2. 3. and 4. a DBA could cause In MODES 5 and 6. the radioactive material to containment. events are reduced due of these probability and consequences limitations of these MODES.

to the pressure and temperature valves are not required Therefore, the containment isolation requirements for containment to be OPERABLE in MODE 5. The6 are addressed in LCO 3.9.4.

isolation valves during MODE "Containment Penetrations."

(continued)

- A~Rev

£*-"

1. 04/07/95 WOG STS

/ 2CXZH

)- Containmentu Isolation ice desr(At-osp Valve

a hnc Dual

) -bl

BASES (continued)

Aod'o i u penetration flow ACTIONS The paths, exceptareforý ACTIONS mo []..inch' a te Valv y purge ing penetration flow all .penetra~tontr°ie paths, to be unisolated intermittently under administrative controls. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In way. the penetration can is indicated. Due when be rapidly isolated a Jthis ation to the

-SC 46 A nee fr the an fc clcs,.rer\3friwfhr OP-' that fjO~ osthe containmen n ion exur aus lineirect cn Y from po-.;it,\ uI.ver M[2A con ainmen atmosp ere to the environment, the penetration co*rv,t',nns a'I -' af flow path containing these valves may not be opened under 4kex,4 44c o+fe, administrativ Iontrols. sing purge va e n a n/e ra i flow pat may b ned to effect re rs to an 0j r-wr4cOA,5 inoper e valve, as allowed/by SR 3.6.3.1.

(U eAz4ep+eý A second Note has been added to provide clarification that, for this LCO. separate Condition acceptable, entry is allowed for each penetration flow path. This is since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable containment isolation valve. Complying with thesubsequent Required Actions may and inoperable allow for continued operation, governed by subsequent containment isolation valves are Required Condition entry and application of associated Actions.

o O*LI The ACTIONS are further modified by a third Note, which eensures appropriate remedial actions arerenderedtaken, if necessary, if the affected systems are inoperable by an inoperable containment isolation valve.

In the event the rock leakage results in exceeding the 0 Note 4 directs entry into @9 1, ii11c 5 overall containment leakageandrate' Required Actions of LCO 3.6.1.

th appl icab-e---onditions A.1 and A.2 In the event one containment isolation4xcept valve in one or more *

.flo aths is leakageinoperable not within forlimit* purgethevalve enetrat, .bun*as or-*-*i*'[d The method "affecte penetration flow path mustof beat isolated. least one isolation of isolation must include the use by a single active barrier that cannot be adversely affected (continued)

B 3.6-33 Rev 1. 04/07/95 WOG STS

BASES ACTIONS A.1 and A,2 (continued) this -criterion are a failure. Isolation barriers that meet containment isolation closed and de.activated automatic c hck (k valve, a closed manual valve, a bl0ind flange, valve secured. For a 01 valve with flow through the penetration flow path isolated in accordance with Required the device used to isolate the penetration Action A.1, to containment.

should be the closest available one A.1 must be completed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The Required Action considering the time 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable,and the relative required to isolate the penetration during importance of supporting containment OPERABILITY MODES 1. 2. 3. and 4.

For affected penetration flow paths that cannot be restored Time and to OPERABLE status within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion with Required that have been isolated in accordance flow paths must be Action A.1. the affected penetration basis. This is verified to be isolated on a periodic that containment penetrations required necessary to ensure and no longer capable to be isolated following an accident will be in the isolation of being automatically isolated Required Action does position should an event occur. This manipulation. Rather. it not require any testing or device walkdown. that those involves verification, through a systemand capable of being isolation devices outside containment The Completion mispositioned are in the correct position. devices outside Time of "once per 31 days for isolation is appropriate considering the fact that the containment controls and the devices are operated under administrative is low. For the isolation probability of their misalignmenttime period specified as devices inside containment, the

".prior to entering MODE 4 from MODE 5 if not performed on engineering within the previous 92 days" is based in view of the judgment and is considered reasonable and other inaccessibility of the isolation devices ensure that isolation administrative controls that will is an unlikely possibility.

device misalignment this by a Note indicating that Condit-ion A has been modified 31-3-2 those penetration to valves. flow paths Condition is only applicable isolation For penetration flow wi wo ontainment ccr paths with only one containment isolation valve and a closed the appropriate actions.

system. Condition C provides (continued)

B 3.6-34 Rev 1. 04/07/95 WOG STS

Containment Isolation Vale Aetý ericD.

ubatmosp i c.-ce .aer dond B 3.6.3 BASES A.1 and A.2 (continued) e I ACTIONS Required Action A.2 is modified byf Notea applies to isolation devices located in high-radiation areas and allows these devices to be verified closed by use of administrative -STP NoL- 2. applhes -I oLt*;A means is arfe ir&-t. Iockel means. Allowing verification by administrative Jev; 1 to these areas is considered acceptable, since access n_ale D~L p*tii or efiae-wia a* ,., EcareJ 4

e typically restricted. _ Therefore, the probability of been verified Idt,. Ge werf,;.J_

h Clsed misa ignment of these devices once they have bq ufof.imini.trative_ to be in the proper position, is small. 7.o A~

7 e .-

nfueans. AIlowi'r~g /ertl~&+A0

,ion sAlao mut include the use of at least one isolation are htcnoIsolation be barriers that affecte.d adversely a singl acie meet thisby criterion are U %te~ failure. a closed manual closed and de-activated automatic valve, is valve, and a blind flange. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is isolated with the ACTIONS accordance of LCOin 3.6.1. In the withevent the Required consistentpenetration affected verified to be Action B.i, the affected penetration must be basis per Required Action A.2. which isolated on a periodic remains in effect. This periodic verification is necessary to penetrations tightnessisolation assure leakrequiring following of containment and anthataccident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact thatthe valves are operated under administrative control and the probability of their misalignment is low. r .",n by a Note indicating this ConditioitP,---1,-

two 1 1)0 Condition B is modifiedpenetration flow paths with LCO is only applicable to A of this isolation valves. Condition containment isolation valve addresses the condition of one containment path.

inoperable in this type of penetration flow (continued)

B 3.6-35 Rev 1. 04/07/95 WOG STS Q1

C~ontairnm:ent lsoain(A~t ric.

uba ms c. c;pLense . and Dual B5J..

BASES ACTIONS (, G2.eVavfev 4 T 3.11.7 (continued)ag ass leakage rate,,t within I Tlo with the jibui-14rn limit, the assumptions of the safety analyses. are 11.a Therefore, the leakage must be restored to within by limit i Restoration can be accomplished to be iso ating-the penetration(s) that caused the limit automatic exceeded by use of one closed and de-activated *."o~

When a valve, closed manual valve. or blind flange. for the isolated penetration is isolated the leakage rate is assumed to be the actual pathway leakage 7penetration isolation devices are through the isolation device. If two leakage rate is assumed r jused to isolate the penetration. the pathwa leakaq of the two devices.

to bethe lesser actual ime.. is r sonable considerin he he..hour pe*e time requ, t ed to restore te akage by isolatin on(s) and the re tve importance of ondary a-" ./-. Co'7,O penetr ainment tILL ~LA.3LM e cant . nt bypass lea e to the overall c (e4 ,"a 14" v.u tion.

b 24 0 E.,.L*E.2. and.E.3 e containment purge valves i one or In the event one or the p valve

,ýeS O eld more penetration paths are not within leakage limits, rge valve leakage must be re red to be must within limits rthe affected penetration f y thepath use of at isolated. method of isolation must least onee solation barrier that canno adversely affect by a single active failure. ed solation barriers t this criterion are a and de-activat d that or blind flange. A a atic valve, closed manual Ve.

rge valve with resilient s s utilized to satisfy equired Action E.1 must - been demonstrated to meet the leakage requirements of 3.6.3.7. The specified Completion Time is re onable, considering that one containment purge ye remains closed so that a gross breach of contai nt does not exist.

In accordan with Required Action E.*22 this pe ration flow path ust be verified to be isolated on periodic basis. periodic verification is neces y tolensure tt Ant-ainment penetrations required cisolated of being fo wnanacdn, hich are no I ger capable

ýol wing a(continued)w WOG ScSBt3.6e37 B 3.6-37 Rev 1. 04/07/95 WOG STS Fw- iA

Containment Isolation Valves (t ei osp "c.y--e~ o ns~eiand Dual BASES ACTIONS (E.1. E.2. and E.3 (continued automatically isolated, w' 1 be in the isolation positi his Required Action does not should an event occur. Rather.,t require any testing o valve manipulation.

hat those involves verificati , through a system walkdown being isolation devices utside containment capable mispositioned a in the correct position. r the isolation dev' es inside containment, the me period a/ 'prior to entering MODE 4 .mMODE 5 if not specified based on performed ithin the previous 92 day 'is enginee ng judgment and is consi ed reasonable in view of the i ccessibility of the isol I on devices and other adn istrative controls that ' ensure that isolation d ice misalignment is an u ikely possibility.

valve with resilient seal )s4* that is For the contaiet pur *_~s SR 3.6.3.

isolated in accordanp be perfond*~ with Required A.tio~n E.1.

must once every[9Jdy.Ti mutb eforme tleast seal is det ed assures that degedto of the resilient t ~ion nehe purge is._

theleakage'rate of the containme vallve does and confirms does It t increase during the time the penettins valve Frequency for SR 3. 6.37 84 days. is based on n he isol ated. NRC normal initiative-, i - Ref.'. 3;).

Since re reliance is placed on a single ye while in he SR more often.

this ondition- it is prudent to perfo [9 days was chosen and /

The fore, a Frequency of once per

eh been shown to be acceptable bas on operating rience.

Times are3 Required Actions and associated Completion

/-if the a MODE in which the*

/ o me , _must be brought to status. the must achieve this

!J LCO does not apply. To Times are

) be brought within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

to at least MODE 3 Completion The allowed within 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months stoand experience, reach the 5 to MODE

(/*.**" based on operating required( conditions from ful1 power conditions in an systems.

orderly manner and without challenging _T (continued)

B 3.6-38 Rev 1, 04/07/95 WOG STS

(D 177S 3. .3 CONTAINMENT SYSTEMS 4-22-94

.;/A CONTAINMENT ISC3LATION VALVES OPERATION LIMITING CONDmON FOR LIMITING CONDmQN FOR OPEATION 3.6.3.1 Each containment isolation valve shall be OPERABLE.* I APpLICABILrT'Y: MODES 1,2,3. and 4.

ACT ION:. n-

p * # - 4 '* " *

.C*[o With one or more of the isolation valves inoperable, maintaini gon CoI.',*^4vA isolation valve OPERABLE in each affected penetration that ist Al:

I a. estore the inoperablevahve(s) to OPEABLE within 4 f4,~ ~~ous "or.. oitoo

b. Isolate each aflected penetrion within " ours by use of at least L3-l7 one deactivated automatic valve secured inn fthe isolation position, or Ar0A- c. Isolate each affected penetration within 4hours by use of at leasto

/,.+,4,, ¢.. I

closed manual valve or blind flange; or k ', j t d. -Be inat least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD oPCA- .SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .,,

IRAI 3_

SURVEILLANCE REQUIREMENTS /ViseA 00- c4f *j .c r 7--vs ,,

4.6.3.1.1 F.o:nta"i+nmernt isolation valve shaall be, ri-nrnstraled--*

-a. Al least once per 92 days by ypgeach weight or sorng loaded

~~check valve testable during p l~perati~on, through one complete cycl of full travel and veri))thaw each check valv remains closed when the differsa pressure in the direction of flow is le than 1.2 psid and opejiwhe n the differential pressure in direction of flow isgrer thanor equal to 1.2 p but es than 5.0 Psi&. _____late__ t______

A"' L.'e.M e.d yet opened on an intermittent basis under I

- Ii NORTH ANNA UNIT- 1 3/4 6-15 Amenldment No.181

/4,/6

4-22-94 CONTAINMENT SYSTEMS V/4.6 3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPFERATION 3.6.3.1 Each containment isolation valve shall be OPERABLE.0 I AppLICAUILfTY: MODES 1,2,-3, and 4.

With one or more of the isolation valves inoperable, maintain **--g j isolation valve OPERABLE in each aflected penetration that is open and:

a. Rentore r inope rable vafry) to OPERAB ,Estab s within 4 Ad.' ,

O.'-I- J e us ofatI so a affeced penetration withir A*-roa I~A one deactivated automatic valve secure in lioiationposztior > A 011' A. A. c. Isolateoeachrnrual penetration affectedvalve withn(ný)hours by use of at least ATC+on A.' Ione or blind ange; or '

A . d. Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and In COLD SHUTDOWN within the following 30 hour&. * .,,t ,*+A (o lit13,,,-

Al \ '

\ it SURVEILLANCE REOUIREMENTS - / oS,- Ac 7on,>,v.s 4,..2_

At least orn-ler 92 days by cycling eacgweight or spring loadW check ya testable during pisat o tion, through one comnle cycJeKof full travel and verifying fttdeach check val remaips

,46sed when the differential ps'vumr in the direction of flo, is less than 1.2 psid and opens when the differential pressuren'the_

direction of flow is greaer,*1an or equal to 1.2 psid but less than 5.

psid. / /

Pro t metring the*v to service after minamt n~ce, repair or" replacement wos-i* performed onthe valve 9r1es assoclated 0 actuator, cornjil or power circit by pertoip~nce of the applicable

,cycling te t~nd verification otsoiston ti. I.

may be opened on an intermittent basis under (2)115 NVoit I NORTH ANNA UNIT- 2 W4 6ý-l 44 Amendment No. 162

-'^oN cor,4a;ýrh4-,+ vacovp, 6rraL"'-ý v4ve)

'Dj-"V1ýe) i,, e3erAar 5 foL bi lc--

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES restore an inoperable specified actions. ITS 3.6.3 does not state the requirement to to take within 4 isolation valve to OPERABLE status, but includes other Actions applicable prior to the hours. ITS LCO 3.0.2 states, "If the LCO is met or no longer of the Required Actions(s) expiration of the specified Completion time(s), completion including the is not required unless otherwise stated." This changes CTS by the allowance.

requirement as part of LCO 3.0.2, rather than explicitly stating in ITS format with This change is acceptable because it retains an existing allowance because it does not ITS usage rules. This change is designated as administrative result in technical changes to the CTS.

and Required Actions for A.5 CTS 3.6.3.1 and CTS 3.6.5.1 do not include any Condition valves inoperable.

one or more penetration flow paths with two containment isolation B states, "One or CTS 3.0.3 would be entered for this Condition. ITS 3.6.3 Condition valves inoperable." ITS more penetration flow paths with two containment isolation flow path by use of at Required Action B.1 states, "Isolate the affected penetration or blind PA-1 least one closed and de-activated automatic valve, closed manual valve, placed in MODE 3 7 the unit be flange," within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . ITS 3.6.3 Condition E requires and associated in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months if the Required Action Actions to be taken for Completion Time is not met. This changes CTS by stating the on CTS 3.0.3, which two containment isolation valves inoperable, rather than relying its MODE of contains the same Completion Times for placing the unit outside Applicability.

in ITS format.

This change is acceptable because it places CTS 3.0.3 requirements result in technical This change is designated as administrative because it does not changes to the CTS.

3.0.4 do not apply." CTS A.6 CTS 3.6.3.1 Action states, "The provisions of Specification specified applicability 3.0.4 states, "Entry into an OPERATIONAL MODE or other Condition for condition shall not be made unless the conditions of the Limiting in the ACTION statements Operation are met without reliance on provision contained exception to ITS 3.0.4.

unless otherwise excepted." ITS 3.6.2 does not contain the or other specified ITS 3.0.4 states, "When an LCO is not met, entry into a MODE the associated condition in the Applicability shall not be made except when MODE or other specified ACTIONS to be entered permit continued operation in the This changes CTS by condition in the Applicability for an unlimited period of time."

incorporating an allowance into ITS LCO 3.0.4.

is changed in ITS such that This change is considered acceptable because LCO 3.0.4 ITS 3.6.2 Actions the NOTE is not required to retain the same CTS requirement.

which together with ITS allow continued operation for an unlimited period of time, This change is designated 3.0.4 result in the same technical requirements as the CTS.

to the CTS.

as administrative because it does not result in technical changes Page 2 Revision 14 North Anna Units 1 and 2

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES is a weight or A.10 CTS 4.6.3.1.1.a requires testing of each containment isolation valve that The ITS does spring loaded check valve testable during unit operation every 92 days.

this Surveillance.

not contain this Surveillance. This changes the CTS by eliminating not changed.

This change is acceptable because the technical requirements have weight or North Anna does not contain any containment isolation valves that are Therefore, this spring loaded check valves which are testable during unit operation.

because surveillance is never performed. This change is designated as administrative it does not result in technical changes to the CTS.

inoperable, A.11 CTS 3.6.3.1 Action states, "With one or more of the isolation valves that is maintain at least one isolation valve OPERABLE in each affected penetration penetration flow open..." ITS Conditions A and B Notes state, "Only applicable to states, "Only paths with two containment isolation valves." ITS Condition C Note valve and a applicable to penetration flow paths with only one containment isolation C.A require the closed system." ITS Condition ITS 3.6.3 Required Actions A.1 and or more associated flow path be isolated by one of the means specified with one ITS 3.6.3 penetration flow paths with one containment isolation valve inoperable.

closed system Required Actions A.1 and C. I both assume the other isolation valve or flow path are OPERABLE for the isolation function. If two valves in a penetration requires t with two containment isolation valves are inoperable, Required Action B.1 the penetration be isolated within one hour, or Condition E is entered, requiring the I -:

hours. In a unit be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and MODE 5 within 36 valve and a closed system, penetration flow path with one containment isolation capable of where the containment isolation valve and the closed system were not This changes performing the isolation function, ITS LCO 3.0.3 would be entered.

of containment CTS by incorporating the concept of assuring that the second means Conditions and Required isolation for a penetration flow path is OPERABLE into the Actions associated with ITS 3.6.3.

flow This change is acceptable because when one means of isolating a containment Required path is inoperable, the other must be OPERABLE, or the ITS requires flow path, Actions be taken for two inoperable means of isolating a containment inoperable means of rather than allowing the Completion Times associated with one of isolating a containment flow path. This retains the CTS 3.6.3.1 concept penetration that maintaining at least one isolation valve OPERABLE in each affected is designated is open when one or more isolation valves are inoperable. This change the CTS.

as administrative because it does not result in technical changes to is established after vacuum has tA If A.12 CTS 4.6.1.1.d states, "Each time containment integrity 63

.3.2 valves in the containment purge been broken by pressure testing the butterfly isolation Applicability is MODES 1, 2, 3, 33 line." The lines and the containment vacuum ejector 4 from and 4. The Frequency for ITS SR 3.6.3.4 states, "Prior to entering MODE the CTS by MODE 5 after containment vacuum has been broken. This changes clarifying adopting the ISTS Frequency format for such a Surveillance Requirement, Page 4 Revision 14 North Anna Units 1 and 2

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES while maintaining Pe41 misinterpreting the requirements of the Surveillance Requirement designated as less restrictive 3., 3 .2I This change is the assumptions of the accident analysis. t I are being applied in the ITS than because less stringent Surveillance Requirements te*f were applied in the CTS.

L.14 Not used.

states that with one or L.15 (Category 3 - Relaxation of Completion Time) CTS 3.6.3.1 in Q41 more isolation valves inoperable, maintain at least one isolation valve OPERABLE OPERABLE status each affected penetration and restore the inoperable valve to 3.(-2 within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.6.3, ACTION D, states that with purge valve penetration hoa leakage not within limit, restore leakage within limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes purge valve penetrations the CTS by relaxing the Completion Time for inoperable from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

leakage is The purpose of CTS 3.6.3.1 is to ensure that containment penetration the Completion Time is within the assumed limit. This change is acceptable because considering the consistent with safe operation under the specified Condition, includes the capacity OPERABLE status of the redundant systems or features. This time for repairs or and capability of remaining systems or features, a reasonable the allowed replacement, and the low probability of a DBA occurring during valve penetration is Completion Time. Allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to repair a leaking purge gross breach of appropriate because the valves are required to be closed and a "Containment." If the containment would fall under the requirement of LCO 3.6.1, 3.6.1, "Containment,"

leakage through the purge valve penetration exceeds the LCO This change is limit, then the ACTIONS of that Specification must be followed.

to restore parameters designated as less restrictive because additional time is allowed to within the LCO limits than was allowed in the CTS.

requires verification that L.16 (Category 4 - Relaxation of RequiredAction) CTS 4.6.1.1.a to be closed are all non-automatic containment isolation valves that are required 3. .

to be closed is found closed every 31 days. If a non-automatic valve that is supposed primary 3.6.3-6 states, "Without open, CTS 3.6.1.1 Action applies. That Action elm CONTAINMENT INTEGRITY within one CONTAINMENT INTEGRITY, restore and in Cold Shutdown hour.or be in at least Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months between within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." ITS 3.6.3 ACTIONS do not differentiate or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate automatic and non-automatic valves and allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , with the inoperable the affected flow path. ITS 3.6.3 allows continued operation and associated Completion containment isolation valve, but if the Required Actions MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is Times are not met, a shutdown to MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 4 allow separate condition required. In addition, ITS 3.6.3 ACTIONS Notes 2, 3 and applicable Conditions and entry for each penetration flow path, require entry into the isolation valves, and Required Actions for systems made inoperable by containment Actions for LCO 3.6.1, require entry into the applicable Conditions and Required results in exceeding the "Containment," when leakage for a penetration flow path Page 16 Revision 14 North Anna Units 1 and 2

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.3 Containment Isolation Valves DOC A.2 (3.6.3-3) DOC A.3 CTS 3.6.1.1 ACTIONS CTS 4.6.1.1.a ITS 3.6.1.3, ACTIONS, SR 3.6.3.1, 3.6.3.2 and Associated Bases NRC RAI: CTS 4.6.1.1 .a verifies that all penetrations not capable of being closed by OPERABLE automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions. The corresponding ITS SRs for this CTS surveillance are ITS SR 3.6.3.1 for valves outside containment and ITS SR 3.6.3.2 for valves inside containment. If CTS 4.6.1.1 .a cannot be met, the ACTIONS of CTS 3.6.1.1 are entered, which require restoration of valve OPERABILITY within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or shutdown within the following 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If ITS SR 3.6.3.1 or ITS SR 3.6.3.2 cannot be met, the ACTIONS of ITS 3.6.3 are entered, which allow for one valve inoperable between 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months depending on the type of penetration to restore valve OPERABILITY before shutdown commences. This Less Restrictive (L) change, along with the addition of ITS 3.6.3 Action Notes 3 and 4, to the CTS is not justified. Refer to Comment Number 3.6.3-6 for ACTION Note 2. Comment: Revise the CTS markup to show this Less Restrictive (L) change and provide the appropriate discussions and justifications.

Response: The Company does not agree with the action recommended in the Comment. The CTS allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore a valve to OPERABLE status or isolate the penetration affected when there is one inoperable valve in a penetration.

CTS 4.6.1.1 .a states, "At least once per 31 days by verifying that all penetrations* not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves, secured in their positions, except for valves that are open under administrative control as permitted by Specification 3.6.3.1 ." Specification 3.6.3.1 Actions a, b, and c allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore the valve or isolate the affected penetration.

There are no other administrative controls in 3.6.3.1 except for these, so one valve in a penetration is allowed to be inoperable for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 3.6.1.1 ACTION states, "Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." This one hour Action criteria would only be applied if both valves in a penetration were inoperable, because CONTAINMENT INTEGRITY would have then been lost. CONTAINMENT INTEGRITY is still maintained when at least one valve in the affected penetration is OPERABLE.

Additional Response: The company agrees with the action recommended in the comment. This replaces the previous response.

CTS 3.6.1.1 Action is revised to eliminate the requirement to restore containment integrity within one hour when a non-automatic containment isolation valve that is this required to be closed is found to be open and the ITS 3.6.3 ACTIONS are applied in

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems DOC L.16 also addresses circumstance. DOC L.16 is added to document the change.

requirements of CTS the application of ITS 3.6.3 ACTION Notes 2, 3, and 4 to the 3.6.3-6.

3.6.1.1. These changes also respond to the concern in RAI

J7,- 3,4d 3 02-09-96 314.6 CONTAINMENT SYSTEMS 3/4.6.1 CONTAINMENT

"*.Th CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION shall be maintained.

3.6.1.1 Primary CONTAINMENT INTEGRITY and 4 *..

APPLICABILITY- MODES 1, 2, 3, Y within mr OTp0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD on our o be in at least HOT STANDBY within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS shall be demonstrated:

r 4..11 Primary CONTAINMENT INTEGRITY of being that all penetrations not capable

a. At least once per 31 days by verifying required to be OPERABLE containment automatic isolation valves and closed by deactivated K5 S- closed by valves,blind flanges, or closed during accident conditions are tha re o en under in their positions,!except for valves 3.C3.- S54 automatic valves, secured 3.6.3.1. e44~t-Cu -Aor0 I-T administrative control as permitted by Specification is-OPERABLE per Specification f* b. By verifying that each containment airlIocM 3.6.1.3.

hatch hatch, by leak rate testing the eqluipmerit

c. After each closing of the equipmet be evaluated or equal to 44.1 psig. Results shall seals, with gas at P, greater than \5,o/

as required by 10 CFR 50, Appendix

"- against the criteria of Specification 3.6.1.2.b the exemptions, and in accordance with 3, Option B, as modified by approved Guide 1.163, dated September 1995.

guidelines contained in Regulatory ite. t tablished vacuum has been broken by ter

d. onirln and the testing the( isolation valves in the containment purge lines pressure containment vacu ejecto l-inetl'e**,

automatic valves which are located inside Except valves, blind flan es, and deactivated osition. hese the containment and are ocked sealed or otherwise sealed in the closed except that such unng each COLD SHUTDOWN penetrations shall be verifie c ose surveillance need not be performed more often -an onc 5 3. 6.3

.' 2 /

3/46-1 Amendment No. 44447-4,41 NORTH ANNA - UNIT 1 GC 4 atu .11

T7-S 3. 6-3 02-09-96 3/4.6 CONTAINMENT SYSTEMS CONTAINMENT 314-6.1 CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION shall be maintained.

3.6.1.1 Primary CONTAINMENT INTEGRITY APPLICABILITY: MODES 1,2, 3, and 4 ACTION;:

next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN o our or e in at least HOT STANDBY within the

, within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS

4. 6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

not capable of being

(.i 7 /

a. At least once per 31 days by verifying that all penetrations*

valves and required to be 3A 1closed by OPERABLE containment automatic isolation 5D1D blind flanges, or deactivated 109..r

-- closed during accident conditions are closed by valves, for valvesrt are o en unde 33.-j. ,

6v_, ' automatic valves, secured in their positions, except S~~~administrative control as permitted by Specification. 3.6.3. 1. 0ot,"u*+,£oL

b. By verifying that each containment air lock is OPERABLE per Specification 3.6.1.3.

by leak rate testing the equipment hatchh

c. A ter each closing of the equipment hatch, seals, with gas at Pa, greater than or equal to 44.1 psig. Results shall be evaluated KI as required by 10 CFR 50, Appendixe against the criteria of Specification 3.6.1.2.b and in accordance with thee J, Option B, as modified by approved exemptions, dated September 1995.

uidelines contained in Regulatory Guide 1.163 itent es i after vacuum has been broken by 3,ý t-z

d. c ontain 593.3.-01 pressure testing thes(* isolation valves in the containment purge lines and the !k containmen cuurp jctc i valves which are located inside

, Except valves, blind flang and deactivated automatic sealed in the closed position. Trh--e,,

the containment and ar ocked sealed or otherwise tat suc,/

penetr sshall be Verified closed during each COLD SHUTDOWN except 5*,3 ,- }-ae need notbe performed more often than once per 92 days...

3/46-1 Amendment No. 99-454462 I LNORTH ANNA - UNST 2 Sle 3, (,-.2 Lj. . ktv 14

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES while maintaining [ 4T misinterpreting the requirements of the Surveillance Requirement 3 3,0'-- I is designated as less restrictive j the assumptions of the accident analysis. This change in the ITS than I Requirements are being applied because less stringent Surveillance were applied in the CTS.

L.14 Not used.

states that with one or L.15 (Category3 - Relaxation of Completion Time) CTS 3.6.3.1 in Q#7 more isolation valves inoperable, maintain at least one isolation valve OPERABLE to OPERABLE status each affected penetration and restore the inoperable valve 3.-2 penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.6.3, ACTION D, states that with purge valve t 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes leakage not within limit, restore leakage within limit within purge valve penetrations the CTS by relaxing the Completion Time for inoperable from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

penetration leakage is The purpose of CTS 3.6.3.1 is to ensure that containment the Completion Time is within the assumed limit. This change is acceptable because considering the consistent with safe operation under the specified Condition, This includes the capacity OPERABLE status of the redundant systems or features.

time for repairs or and capability of remaining systems or features, a reasonable during the allowed replacement, and the low probability of a DBA occurring purge valve penetration is Completion Time. Allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to repair a leaking and a gross breach of appropriate because the valves are required to be closed 3.6.1, "Containment." If the containment would fall under the requirement of LCO the LCO 3.6.1, "Containment,"

leakage through the purge valve penetration exceeds be followed. This change is limit, then the ACTIONS of that Specification must is allowed to restore parameters designated as less restrictive because additional time to within the LCO limits than wasI allowed in the CTS.

requires verification that L.16 (Category 4 - Relaxation of Required Action) CTS 4.6.1.1.a to be closed are all non-automatic containment isolation valves that are required 3. . ,

to be closed is found closed every 31 days. If a non-automatic valve that is supposed primary 3.6-3 states, "Without open, CTS 3.6.1.1 Action applies. That Action INTEGRITY within one le of CONTAINMENT INTEGRITY, restore CONTAINMENT and in Cold Shutdown hour or be in at least Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months do not differentiate between within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." ITS 3.6.3 ACTIONS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate automatic and non-automatic valves and allow 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , operation with the inoperable the affected flow path. ITS 3.6.3 allows continued and associated Completion containment isolation valve, but if the Required Actions and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is Times are not met, a shutdown to MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3 and 4 allow separate condition required. In addition, ITS 3.6.3 ACTIONS Notes 2, the applicable Conditions and entry for each penetration flow path, require entry into isolation valves, and Required Actions for systems made inoperable by containment for LCO 3.6.1, require entry into the applicable Conditions and Required Actions path results in exceeding the "Containment," when leakage for a penetration flow Page 16 Revision 14 North Anna Units 1 and 2

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES changes the CTS by overall containment leakage rate acceptance criteria. This flow path affected by an providing 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to isolate a penetration and allowing continued inoperable non-automatic containment isolation valve, isolation valve. This also operation with an inoperable non-automatic containment for each penetration flow path changes the CTS by allowing separate condition entry valve, requiring entry into the with an inoperable non-automatic containment isolation made inoperable by applicable Conditions and Required Actions for systems and requiring entry into the inoperable non-automatic containment isolation valves, 3.6.1, "Containment," when applicable Conditions and Required Actions for LCO non-automatic leakage through a penetration flow path due to an inoperable containment leakage rate containment isolation valve results in exceeding the overall acceptance criteria.

overall containment leakage rate The purpose of CTS 3.6.1.1 Actions is to ensure that This change is acceptable because does not exceed the accident analysis assumptions.

that must be taken in the Required Actions are used to establish remedial measures risk associated with response to the degraded conditions in order to minimize features. The Required continued operation while providing time to repair inoperable specified Condition, considering Actions are consistent with safe operation under the features, the capacity and the operability status of the redundant systems of required repairs or replacement of capability of remaining features, a reasonable time for occurring during the repair required features, and the low probability of a DBA non-automatic containment period. This change makes the actions for an inoperable types of containment isolation isolation valve consistent with the actions for all other flow path affected by an valves and ensures that leakage through a penetration is isolated. This change is inoperable non-automatic containment isolation valve Required Actions are being designated as less restrictive because less stringent applied in the ITS than were applied in the CTS.

Page 17 Revision 14 North Anna Units 1 and 2

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.3 Containment Isolation Valves DOC A.8 (3.6.3-6) CTS 3.6.1.1 ACTION CTS 3.6.3.1 ACTIONS CTS 3.6.5.1 ACTION ITS 3.6.3, ACTIONS NOTE 2 are modified by the addition NRC RAI: CTS 3.6.3.1 ACTIONS and CTS 3.6.5.1 ACTION as an Administrative of ITS 3.6.1.3 ACTIONS Note 2. This change is characterized for CTS 3.6.3.1 and 3.6.5.1, it still change (DOC A.8). While this change is acceptable 3.6.1.1 as a result of Comment needs to be addressed for the changes imposed on CTS ACTIONS Note 2 becomes a Number 3.6.3-3. For that change, the addition of ITS 3.6.3 statement of 3.6.1.1 implies Less Restrictive (L) change, because nothing in the ACTION and provide the separate condition entry. Comment: Revise the CTS markup (L) change. Refer to appropriate discussions and justifications for this Less Restrictive Comment Number 3.6.3-3.

in the Response: The Company does not agree with the action recommended CTS Restrictive change.

Comment. The Company does not agree that this is a Less not capable all penetrations*

4.6.1.1 .a states, "At least once per 31 days by verifying that containment automatic isolation valves and required to of being closed by OPERABLE flanges, or deactivated be closed during accident conditions are closed by valves, blind that are open under automatic valves, secured in their positions, except for valves Specification 3.6.3.1 administrative control as permitted by Specification 3.6.3.1."

valve or isolate the affected penetration.

Actions a, b, and c allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore the except for these, so the valves are There are no other administrative controls in 3.6.3.1 allowed to be inoperable for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

recommended in the Additional Response: The company agrees with the action comment. This replaces the previous response.

to restore containment CTS 3.6.1.1 Action is revised to eliminate the requirement containment isolation valve that is integrity within one hour when a non-automatic ITS 3.6.3 ACTIONS are applied in this required to be closed is found to be open and the DOC L.1 6 also addresses circumstance. DOC L.1 6 is added to document the change. 3.6.1.1.

of CTS the application of ITS 3.6.3 ACTION Note 2 to the requirements found in the response to RAI The revised submittal pages affected by this change are 3.6.3-3.

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.3 Containment Isolation Valves JFD 4 (3.6.3-12) Bases JFD 2 Bases JFD 7 STS SR 3.6.3.8 and Associated Bases ITS SR 3.6.3.4 and Associated Bases isolation valve (CIV)

NRC RAI: STS SR 3.6.3.8 verifies that each automatic containment its isolation that is not locked, sealed or otherwise secured in position actuates to STS SR 3.6.3.8 by adding "power operated" between position. ITS SR 3.6.3.4 modifies "automatic" and "containment." The justification used for this change (JFD 4) states that automatic. The the change is to clarify that only power-operated CIVs are considered not considered as automatic valves.

implication of this change is that check valves are B3.6.3 Bases - BACKGROUND This reasoning is carried over to changes made to ITS the following:

and the associated Bases JFD 7. STS B3.6.3 - BACKGROUND states deletes "Check valves, or other automatic valves..." ITS B3.6.3 Bases - BACKGROUND states that check the words "Check valves, or other" by Bases JFD 7. The justification check valves, when valves are not considered active devices. The staff's position is that devices. STS used as CIVs, are considered as automatic valves and thus are active in STS B3.6.3 3.6.3 Bases - BACKGROUND states this position and the discussion between automatic power-operated Bases - LCO reaffirms it when it differentiates found in 10 CFR isolation valves and check valves. The Bases for this position can be 57, which state that check valves 50 Appendix A, General Design Criteria 55, 56, and for certain types of may not be used as one of the automatic isolation valves In addition, the change penetrations. Thus the staff finds these changes unacceptable.

of review for this made in ITS SR 3.6.3.4 is considered generic and beyond the scope conversion. Comment: Delete these changes.

in the Response: The Company does not agree with the action recommended valves are automatic, active Comment. The North Anna design assumes that check of from the standpoint devices for functional purposes, but are passive components single failure and system design.

ITS 3.6.3 JFD 4 is modified to state that for functional purposes, check valves are Adding the term active or automatic devices, but do not receive an actuation signal.

"power operated" in ISTS SR 3.6.3.8 clarifies that only power-operated valves receive an as part of ISTS actuation signal, and the automatic function of check valves is verified SR 3.6.3.9.

Information Report

ITS 3.6.3 Bases JFD 7 is modified to explain that consistent with as active SECY-77-439, dated August 17, 1977, "Check valves are classified inspection, testing, components for the purposes of functional specification, inservice as passive and valve design (re: Regulatory Guide 1.146). Check valves are classified The reference in the components for the purposes of single failure and system design."

failures of ISTS 3.6.3 Bases that is deleted is part of a discussion that addresses is not that case for check automatic valves for the purposes of single failure, which valves at NAPS.

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems is not licensed to these Regarding the GDC 55, 56, and 57 references, North Anna Anna UFSAR Chapter 3 GDCs in 10 CFR 50 Appendix A, but the criteria in the North dated October 15, 1975, the read the same way. In the NAPS response to comments were shown to all be inside valves identified as being containment penetration valves 56, and 57 references that containment. North Anna UFSAR Chapter 3 and GDC 55, valves state that simple check exclude check valves from being used as automatic outside containment.

valves may not be used as the automatic isolation valve the NRC, the portions of the Additional Response: Based on verbal comments from The revisions to ITS JFD 4 and previous response marked with an asterisk are modified.

in the updated pages. The Bases JFD 7 discussed in the response were not provided revised pages are provided.

"power operated." This ITS SR 3.6.3.5 is revised to eliminate the added phrase to state that check valves eliminates ITS JFD 4. The Bases for SR 3.6.3.5 are revised automatic valves for the which are containment isolation valves are not considered receive a containment isolation purpose of the Surveillance as the check valves do not The change reflects the North signal. Bases JFD 8 is added to explain this change.

as containment isolation valves.

Anna - specific allowance to credit some check valves

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS FREQUENCY SURVEILLANCE RAI Verify each automatic containment isolation 18 months 3.6.3-2 SR 3.6.3.5 RAI 3.6.1-5 valve that is not locked, sealed or Ri otherwise secured in position, actuates to RAI 3.6.3-12 the isolation position on an actual or R14 simulated actuation signal.

RAI 3.6.3-2 18 months SR 3.6.3.6 Cycle each weight or spring loaded check RAI 3.6.1-5 valve not testable during operation through Ri one complete cycle of full travel, and verify each check valve remains closed when the differential pressure in the direction of flow is < 1.2 psid and opens when the differential pressure in the direction of flow is - 1.2 psid and < 5.0 psid.

3.6.3-6 Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.3.5 Automatic containment isolation valves close to prevent on a leakage of I3.

RAI 3.6.3-2 RAI RI RAI 3.6.3-12 containment isolation signal R14 following a DBA. This radioactive material from containment operated containment SR ensures that each automatic power position on a isolation valve will actuate to its isolation are containment isolation signal. Check valves which considered automatic containment isolation valves are not they do not valves for the purpose of this Surveillance as is This Surveillance receive a containment isolation signal. sealed, or not required for valves that are locked, otherwise secured in the required position under is based on administrative controls. The 18 month Frequency conditions the need to perform this Surveillance under the for an that apply during a unit outage and the potential were performed with unplanned transient if the Surveillance has shown that the reactor at power. Operating experience when these components usually pass this Surveillance the performed at the 18 month Frequency. Therefore, a reliability Frequency was concluded to be acceptable from standpoint.

13.6.3-2 SR 3.6.3.6 RAI 3.6.1-5 function The check valves that serve a containment isolation RAI to provide positive closure in are weight or spring loaded valves the direction of flow. This ensures that these check will remain closed when the inside containment atmosphere DBA.

returns to subatmospheric conditions following avalves that SR 3.6.3.6 verifies the operation of the check of are not testable during unit operation. The Frequency of 18 months is based on such factors as the inaccessibility down to these valves, the fact that the unit must be shut the tests on perform the tests, and the successful results of an 18 month basis during past unit operation.

REFERENCES 1. UFSAR, Chapter 15.

2. Technical Requirements Manual.

3. Standard Review Plan 6.2.4.

RAI 3.6.3-14

4. UFSAR, Section 6.2.4.2. RI B 3.6.3-11 Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2

Containment Isolation Ice ýVae&lvemsp (As]ric.,

r ua_c

ýuansp~eric c.c. .(o'~ (Atnos

)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.O Perform leakage rate testing for rnntainrnn nm "ma v*Ivac with resilient (JO seals.

O ft Ia4

VO( oP M ~ 4 a5 e~ re AL~ ~

SR 3,6.3.( Verify each automatic containment isolation E181 months valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

4.c.3. L.J SR 3.6.3.OPI Cycle each weight or spring loaded check 18 months valve not testable during operation through one complete cycle of full travel, and verify each check valve remains closed when the differential pressure in the direction of flow is ,'f1.2rpsid and opens when the differentia rpressure in the Oirectign of flow is X{1.21Dpsid and N<

45"O]psid.

SR 3.6.3.10 Verify each [I inch containment purge [18] months valve is blocke 4 restrict the valve from opening > [50Jt.

(continued)

WOG STS 3.6-14 Rev 1. 04/07/95

JUSTIFICATION FOR DEVIATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES

1. The headings for ISTS 3.6.3 include the parenthetical expression (Atmospheric, Subatmospheric, Ice Condenser, and Dual). This identifying information is not included in the NAPS ITS. This information is provided in the NUREG to assist in identifying the appropriate specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific implementation. Therefore, necessary editorial changes were made.

2. The brackets are removed and the proper plant-specific information/value is provided.

3. Conditions, Surveillance Requirements and other references to shield building bypass are j .

not retained. Shield building bypass is not part of the NAPS design.

W

4. Not used.

5. ITS SR 3.6.3.6 requires each weight or spring loaded check valve used as a containment isolation valve that can be tested during operation to be tested through one complete cycle of travel every 92 days. North Anna CTS Surveillance 4.6.3.1.1 contains a similar requirement. ITS SR 3.6.3.6 is deleted as North Anna does not contain weight or spring loaded check valves used as containment isolation valves that are testable during operation. Therefore, this Surveillance does not apply.

6. ISTS 3.6.3 ACTIONS NOTE 4 is modified to clarify that entry is required into the applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when leakage for a penetration flow path, instead of when isolation valve leakage, results in exceeding the overall containment leakage rate acceptance criteria. The Containment is not inoperable if there is still an OPERABLE containment isolation valve in the affected flow path. This change is acceptable because ISTS 3.6.3 Required Action A.1 allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to isolate the affected penetration flow with one or more penetration flow paths with one containment isolation valve inoperable. If Required Action A.1 and its associated Completion Time is not met, the unit is required to be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This is consistent with ISTS 3.6.1 which requires an is inoperable Containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or the unit required to be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This is also consistent with the current licensing basis.

£1.r

7. ISTS 3.6.3 ACTION E is not adopted. The Reviewer's Note to TSTF-205, Rev. 5, states that either ACTION D or ACTION E is applicable. ACTION D is applicable to the 3o6.3-2 are I I, North Anna design, therefore, ACTION E i's not adopted. Subsequent requirements accordingly.

numbered and lettered I:

The bracketed term "or more," added to ISTS 3.6.3 Condition A Note, Condition B Note, 8.

and Condition B, is not adopted. At NAPS, only two valves in each penetration addressed by Conditions A and B are required. This consistent with the current licensing basis.

North Anna Units 1 and 2 Page I Revision 14

Containment Iso~lation Valve (Atmo'P Iric.

.uba moSp i1c,ce- on ~isert7-nd Dual')

B3.6.3

©0 BASES SURVEILLANCE -SR 3.6.3.-*)

REQUIREMENTS 3.b3-Z (continued) For containment purge valves with resilient seals, '3.L.1 -if additional leakage rate testing beyond the test requirements T5TF -wr 3.4 1-5ý of l.0CFR 50. Appe*djxjj "is required to ensure OPERABILITY. k. ,

Operating experience has demonstrated that this type of seal doohrsa tps*_.-/Based on this obs~ervation4rd- dh*e has the potential to dporade in penetration dirctpl*tinngthis a shorter.iot le tight odon (due han.

and treai tmornc tnvronet) rn the diet th between containment laFrequ~en/cy It84 days was established as pnat of the NC resolutionf Generic C) Issue B-20, "Contaii n ~Leakage ekg De) u to Seal eioration' (Ref. 3).

(ddi - a

I-) his SR u e p rformed ft-h i .03-dayz aft~er "ain n va t cyc ig the valveeuency could was cnosen introduce additional seal~deg~radation (beyond us. ýthat ntoa fc that has not been o ned. tecrea'ng te r*ntervT-I~iiml ays) is a prudent meas~p'after a valve

,has been o.pene...

SR 3-6-34 iptry,-,.

rs F*,*fq-."'7; Automatic contairnment isolation valves close on a 5

P11

"~ ,*, I containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This ensures that each automatic containment isolation valve SR a containment will actuate to its isolation position on This surveillance is not required for hva yes thatsignal.

isolation are ocked. sealed. or otherwise secured in the L4ai7ect4red "I sition under administrative controls. The outage S/ monthFrequency (I9S and the potential is based on the need to perform this 13L) for an unplanned conditions that apply transient during ifa 4ithe 0

urveillance under the Surveillance were performed with the reactor at power.

usually Operating experience has shown that these components pass this Surveillance when performed at the-lB)'IBmonth to be Frequency. Therefore, the Frequency was concluded acceptable from a reliabilit stand int.

,C k ' "(continued)

B 3.6-42 Rev 1. 04/07/95 WOG STS

JUSTIFICATION FOR DEVIATIONS ITS 3.6.3 BASES, CONTAINMENT ISOLATION VALVES the plant

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect basis specific nomenclature, number, reference, system description, analysis, or licensing description.

2. Changes are made to reflect those changes made to the ISTS. The following requirements are renumbered or revised, where applicable, to reflect the changes.

has been

3. The brackets have been removed and the proper plant specific information/value provided.

4. The criteria of the NRC Final Policy Statement on Technical Specifications in the Improvements have been included in 10 CFR 50.36(c)(2)(ii). Therefore, references to reference ISTS Bases to the NRC Final Policy Statement are revised in the ITS Bases 10 CFR 50.36.

5. Typographical/grammatical error corrected.

not be used to

6. The sentence in the ACTIONS C.1 and C.2 Bases, "A check valve may isolate the affected penetration flow path" is modified. The phrase, ", with the exception of valves specified in Reference 4" is added to the sentence. Reference 4, UFSAR four section 6.4.2.1, is added to the References. UFSAR section 6.4.2.1 specifies conjunction containment penetrations which use check valves outside of containment in with a closed system.

7. The Bases are changed to eliminate a statement classifying check valves as active 3.9-3-r2 devices. Information Report SECY-77-439, dated August 17, 1977, states, "Check valves Rq specification, inservice are classified as active components for the purposes of functional valves are inspection, testing, and valve design (re: Regulatory Guide 1.146). Check design."

classified as passive components for the purposes of single failure and system that addresses The reference in the ISTS 3.6.3 Bases that is deleted is part of a discussion is not accurate for failures of automatic valves for the purposes of single failure. This check valves at North Anna.

8. The Bases of SR 3.6.3.5 are revised to exclude check valves from the SR performance. PAY SR 3.6.3.5 requires verification that automatic containment isolation valves close on a 3, 12 as t? iq containment isolation signal. North Anna is allowed to utilize some check valves containment containment isolation valves. These check valves are considered automatic

, testing and isolation valves for the purpose functional specification, inservice inspection valves do not valves design. However, check valves serving as containment isolation be performed receive a containment isolation signal. Therefore, this Surveillance cannot on check valves.

Revision 14 North Anna Units 1 and 2 Page I Revision 14

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.7 Recirculation Spray (RS) System DOC L.2 (3.6.7-3) CTS 3.6.2.2 ACTION a CTS 3.6.2.2 ACTION b CTS 3.6.2.2 ACTION c ITS 3.6.7 Required Action E.2 and Associated Bases STANDBY (MODE 3) is NRC RAI: CTS 3.6.2.2 ACTION a requires that after HOT to OPERABLE status within reached, the action is to "restore the inoperable subsystem next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." CTS 3.6.2.2 the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in COLD SHUTDOWN within the markup by a similar statement. This ACTIONS b and c have been modified in the CTS corresponding ITS ACTION is ITS modification is Insert 2 and justified by DOC L.2. The 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months .

in MODE 5 within 3.6.7 Required Action E.2, which requires the plant to be of 84 hours does ACTIONS Even though the overall time to complete the CTS and ITS converting the is a change in not change (CTS 6to MODE 3 +48 + 30 = 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months ), there shutting down to of CTS to the ITS. This change relates to when the commencement CTS it officially starts immediately after the 48 MODE 5 begins or is declared. In the status is completed.

hour allowed outage time to restore the subsystem to OPERABLE is not indicated 3 is reached. This change In the ITS it beings immediately after MODE incorrect for a, and Insert 2 is or justified in the CTS markup for CTS 3.6.2.2 ACTION with CTS 3.6.2.2 ACTION a is a CTS 3.6.2.2 ACTIONS b and c. The change associated 5 declared to MODE More Restrictive change (Time for commencement of shutdown ACTIONS b and c 3.6.2.2 earlier in ITS versus CTS). The change associated with CTS changed to and the 30 hours is still Less (L) Restrictive, but Insert 2 should be deleted, and the CTS markup 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months , with the appropriate justification. Comment: Revise and justifications for these More Restrictive and Less provide the appropriate discussions Restrictive (L) changes.

in the Comment, with certain Response: The Company will take the action proposed markup is modified, DOC L.2 modifications. ITS 3.6.7 CTS Insert 2 is deleted, the CTS to the CTS. The time for is modified, and DOC M.1 is added to explain the change 5 is changed from up to 54 declaring commencement of Action to place the unit in MODE hours after entering ACTIONS b and c to immediately.

1 and 2, was modified by the Additional Response: CTS markup page 2 of 4 for Units but the revised page was not deletion of Insert 2 as discussed in the previous response, included. These pages have been provided.

ITS 3.6.7, RECIRCULATION SPRAY SYSTEM 3,RAI INSERT or two inside RS subsystems inoperable, Page 2 of 4 Revision 14 North Anna Units 1 and 2

ITS 3.6.7, RECIRCULATION SPRAY SYSTEM RAI INSERT or two inside RS subsystems inoperable, Page 2 of 4 Revision 14 North Anna Units 1 and 2

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 3.6.7 Recirculation Spray (RS) System Bases JFD 6 (3.6.7-4) STS B3.6.6E Bases - E.1 ITS B3.6.7 Bases - D.1

'The 72 NRC RAI: The last sentence in STS B3.6.6E Bases - E.1 states the following:

as given in Required hour Completion Time was chosen based on the same reasons sentence and Action B.1 ." The ITS markup of ITS B3.6.7 Bases - D.1 deletes this These replaces it with sentences on casing cooling tank and RS pump OPERABILITY.

Time as does new sentences do not provide a justification for the 72-hour Completion ITS markup to either retain the STS wording the STS statement. Comment: Revise the 72-hour Completion Time for ITS 3.6.7 or provide plant-specific wording justifying the and justifications as Required Action D.1 and provide the appropriate discussions necessary.

The STS Response: The Company will take the action proposed in the Comment.

wording is retained.

wording in the Additional Response: The previous response is superceded. The STS Anna design. The originally Required Action D.1 Bases is not consistent with the North cooling tank inoperability proposed wording describing the relationship between casing describing the and RS subsystem inoperability is restored. The STS Bases wording basis for the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is retained.

RS System B 3.6.7 BASES D.1 (continued) 3.6.7-4 ACTIONS Ri, R14 condition are capable of providing 100% of the heat removal needs after an accident. The casing cooling tank does not affect the OPERABILITY of the inside RS subsystem pumps. The effect on NPSH of the outside RS pumps must be assessed as part of outside RS pump OPERABILITY. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was chosen based on the same reasons as given in Required Action B.1.

E.1 and E.2 tank If the inoperable RS subsystem(s) or the casing cooling cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 is within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. The extended interval to reach MODE 5 allows additional time and is reasonable considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

F.1 an With an inoperable inside RS subsystem in one train, and inoperable outside RS subsystem in the other train, only 1800 containment spray coverage is available. This condition is outside accident analysis. With three or more RS subsystems inoperable, the unit is in a condition outside the accident analysis. With two inoperable outside RS subsystems, less all than 100% of required RS flow is available. Therefore, in three cases, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.6.7.1 REQUIREMENTS Verifying that the casing cooling tank solution temperature is within the specified tolerances provides assurance that the water injected into the suction of the outside RS pumps will increase the NPSH available as per design. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of this SR was developed considering operating experience related to the parameter variations and instrument drift during the applicable MODES. Furthermore, (continued)

B 3.6.7-6 Rev 14 (Draft 4), 01/31/02 North Anna Units 1 and 2

RS System ((S tCLh)~~-j,

~B3.6.g~f()

BASES ACTIONS D. (continued chosen base. on the same. asons as giv in Required Action B.

With he casing cooling tank inoperable, the NPSH available to&R*outside RS subsystem pumps may not'be sufficient.

The inoperable casing cooling tank must be restored OPERABL* _atus within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 1 onents in thi degr5Ad condi ion a -capa le of iding 100X of e hea Lre*val needs after an . he 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion qime was cnosen based on the same reasons as given in

01) 1Reauird .2io 7 B,. /V-Jo H

, ------, _0o £~* .

If the inopera e ubsystem(s) or the casing cooling tanK cannot be restored t-Q OPERABLE status within the required Comp etion mine. the must be brought to a MODE in which the LCO does not apply. To achieve this status, the must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and oDE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience. to 0reach MODE 3 from 11 ower conditions in an orderly manner and wi ou c a ienging systems. The extended interval to reach MODE a ows additional time and is reasonable considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

With three or more RS subsystems inoperable, the unit is in a condition outside the accident analysis. Therefore, (. +b LCD 3.0.3 must be entered immediately.

, . ' "oL .

kJ 1SýOn1-k cLv oerwA l,tr' e c~-'De- Outlr (continued)

WOG STS B 3.6-105 Rev 1. 04/07/95 I 4A'tw" Iar, d6 4K 1 0'%

-4 ,,j g $ L~

Ppr4 ý c-i-. j-tA4 ! !n

Changes to ITS Submittal Not Associated With RAts ITS Section 3.6, Containment Systems are modified to The Background Bases of Specification 3.6.7, Recirculation Spray, OPERABILITY and Recirculation clearly state the relationship between Quench Spray Spray OPERABILITY.

RS System B 3.6.7 BASES BACKGROUND cooling tank. The casing cooling pumps are considered part (continued) of the outside RS subsystems. Each casing cooling pump is powered from a separate ESF bus.

is increased by reducing R14 The inside RS subsystem pump NPSH the temperature of the water at the pump suction. Flow is RS diverted from the QS system to the suction of the inside pump on the same safety train as the quench spray pump supplying the water.

The RS System provides a spray of subcooled water into the upper regions of containment to reduce the containment pressure and temperature during a DBA. Upon receipt of a High-High containment pressure signal, the two casing cooling pumps start, the casing cooling discharge valves open, and the RS pump suction and discharge valves receive an open signal to assure the valves are open. After a 195+/-9.75 second time delay, the inside RS pumps start, and after a 210+/-21 second time delay, the outside RS pumps start. The RS pumps take suction from the containment sump and discharge through their respective spray coolers to the is spray headers and into the containment atmosphere. Heat the containment sump water to service water transferred from in the spray coolers.

The Chemical Addition System supplies a sodium hydroxide of (NaOH) solution to the RWST water supplied to the suction the QS System pumps. The NaOH added to the QS System spray ensures an alkaline pH for the solution recirculated in the containment sump. The resulting alkaline pH of the RS spray to (pumped from the sump) enhances the ability of the spray scavenge iodine fission products from the containment atmosphere. The alkaline pH of the containment sump water minimizes the evolution of iodine and minimizes the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to the fluid.

to The RS System is a containment ESF system. It is designed capability required during the ensure that the heat removal QS and post accident period can be attained. Operation of the heat removal capability to RS systems provides the required limit post accident conditions to less than the containment to design values and depressurize the containment structure subatmospheric pressure in < 60 minutes following a DBA.

The RS System limits the temperature and pressure that could be expected following a DBA and ensures that containment leakage is maintained consistent with the accident analysis.

B 3.6.7-2 Rev 14 (Draft 1), 01/10/02 North Anna Units 1 and 2

RS System at B %.

B 3.6 CO AINMENT SYSTEMS B 3.6.. )Recirculation Spray (RS) System (i ph c) 0 BASES BACKGROUND The RS System, operating in conjunction with the Quench Spray (QS) System. is designed to limit the post accident pressure and temperature in the containment to less than the design values and to depressurize the containment structure to a subatmospheric pressure in less than 60 minutes following a Design Basis Accident (DBA). The reduction of containment pressure and the removal of iodine from the containment atmosphere by the spray limit the release of fission product radioactivity from containment to the environment in the event of a DBA.

The RS System consists of two separate trains of equal capacity. each capable of meeting the design and accident bases. Eachandtrain analysis containment includes one RS subsystem outside one RS subsystem inside containment.

Each subsystem consists of one 50% capacity spray pump. one spray cooler, one 1800 coverage spray header, nozzles.

valves, piping, instrumentation, and controls. Each outside RS subsystem also includes a casing cooling pump with its own valves, piping, instrumentation, and controls. The two outside RS subsystems' spray pumps are located outside containment and the two inside RS subsystems' spray pumps are located inside containment. Each RS train (one inside and one outside RS subsystem) is powered from a separate Engineered Safety Features (ESF) bus. Each train of the RS System provides adequate spray coverage to meet the system design requireme ts for containment heat and iodine fission product removal1. 04 I The two casing cooling pumps and common casing cooling tank to,,ýa JAoe are designed to increase the net positive suction head 5ýro T h (NPSH) available to the out *de RS pumps by injecting cold water into the tank suction of t spray pumps. The casin coolingwC~7w*_ contains 16,500 gal of c i ed and borated water. Each casing cooling pump supplies one outside spray pump with cold borated water from the casing t

I I cooling artank. The casing cooling pumps are considered part of the outside RS subsystems. Each casing cooling pump is powered from a separate ESF bus.

or ff'oooiA-sr,' P,6 T4 Y4(e,ý- J; iv AM.I.

0Z

+O1r

A +ke A-&0AnQ,.(

(vi 4, ff

-ý B 3.6-100 i Rev 1. 04/07/95

' H Fe(c,V. 1q

ITS 3.6.7 BASES, RECIRCULATION SPRAY SYSTEM INSERT temperature of the 14 The inside RS subsystem pump NPSH is increased by reducing the (OS) system to the water at the pump suction. Flow is diverted from the Quench Spray the quench spray pump suction of the inside RS pump on the same safety train as supplying the water.

Insert to Page B 3.6-100 Revision 14 North Anna Units 1 and 2

Attachment Proposed Improved Technical Specifications Changes Not Associated with RAIs Virginia Electric and Power Company (Dominion)

North Anna Power Station Units 1 and 2

Specifications Affected: ITS 1.1, SDM Definition Description to include the sentence, TSTF-248 revised the SHUTDOWN MARGIN (SDM) definition means, it is not necessary "However, with all RCCAs verified fully inserted by two independent was added to the North Anna to account for a stuck RCCA in the SDM calculation." TSTF-248 determined that this sentence is not ITS in Supplement 2. Subsequent to its incorporation, it was two independent means to verify applicable to North Anna, as the plant design does not provide used, it is removed to avoid that an RCCA is fully inserted. As the allowance cannot be confusion.

Definitions 1.1 i.1 Definitions

b. Authorized under the provisions of PHYSICS TESTS 10 CFR 50.59; or (continued)

c. Otherwise approved by the Nuclear Regulatory Commission.

upper QPTR shall be the ratio of the maximumthe average QUADRANT POWER TILT excore detector calibrated output to RATIO (QPTR) outputs, of the upper excore detector calibrated excore detector or the ratio of the maximum lower of the lower calibrated output to the average whichever is excore detector calibrated outputs, greater.

heat transfer RTP shall be a total reactor core 2893 MWt.

RATED THERMAL POWER rate to the reactor coolant of (RTP) time interval The RTS RESPONSE TIME shall be thatexceeds its RTS REACTOR TRIP SYSTEM from when the monitored parameter (RTS) RESPONSE TIME until loss of trip setpoint at the channel sensor stationary gripper coil voltage. The response time of may be measured by means of any series so that steps sequential, overlapping, or total In lieu of the entire response time is measured.

verified for measurement, response time may be the components selected components provided that have been and methodology for verification by the NRC.

previously reviewed and approved of SDM shall be the instantaneous amount or SHUTDOWN MARGIN (SDM) is.subcritical reactivity by which the reactorpresent condition would be subcritical from its assuming:

(RCCAs) are

a. All rod cluster control assemblies RCCA of fully inserted except for the single assumed to highest reactivity worth, which is not capable be fully withdrawn. With any RCCA worth R13 of being fully inserted, the reactivity for in the of the RCCA must be accounted determination of SDM; and

b. In MODES 1 and 2, the fuel and moderator zero temperatures are changed to the nominal power design level.

.. 111 _ Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

Definitions 1.1 6 IM 11 Definitions

a. All rod cluster control assemblies (RCCAs) are SHUTDOWN MARGIN (SDM) fully inserted except for the single.RCCA ofto f1JŽ,' /l/13 (continued) worth, which is assumed highest reactivity be fully withdrawn.': With any RCCA not capable-*

of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and

b. In MODES 1 and 2, the fuel and mo~rator zero temperatures are changed to theEfiominal power design levelJ-S A SLAVE RELAY TEST shall consist of energizing of

ý and verifying the OPERABILITY ea *slave r ay. The SLAVE RELAY TEST shall include4 'mJ a continuity check of assoc atedtestable actuation devices A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals.

where n. is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TRIP ACTUATING DEVICE A TADOT shall consist of operating the trip of T-5rf OPERATIONAL TEST actuatin aasdevice and verifying 2the OPERABILITY ment (TADOT) cti e TADOT s all adjustment.

includewithin as actuates at the necessary, of the required trip setpoint actuating device sothe that it

(*e*.*'* * ~accuracy".*'- '.

A ll *d ~ e

~tiI deAL'-',

.,,eat",o.,-:S.rII!

dexOr 1.1-6 Rev 1. 04/07/95 WOG STS kt, 13

JUSTIFICATION FOR DEVIATIONS CHAPTER 1.0, USE AND APPLICATION is provided.

1. The brackets are removed and the proper plant specific information/value Limits Report (PTLR)

2. The Company does not propose to use a Pressure and Temperature from the Technical and will not relocate the Pressure and Temperature limits the ITS. Therefore, the definition of Specifications. The current limits will be retained in PTLR was not incorporated in the ITS.

allows an exception to the I?13

3. TSTF-248 was not incorporated into the ITS. TSTF-248 rod if all rods can be verified SHUTDOWN MARGIN definition to not assume a stuck does not provide two independent inserted by two independent means. The plant design allowance cannot be used and is means to verify a rod is fully inserted. Therefore, the removed to avoid confusion.

North Anna Units 1 and 2 Revision 13 I

CHAPTER 1.0, USE AND APPLICATION INSERT 1 verified for selected In lieu of measurement, response time may be for verification components provided that the components and methodology the NRC.

have been previously reviewed and approved by INSERT 2 any series of sequential, The response time may be measured by means of response time is measured.

overlapping, or total steps so that the entire INSERT 3 the reactivity With any RCCA not capable of being fully inserted, determination of SDM; worth of the RCCA must be accounted for in the and are changed to

b. In MODES 1 and 2, the fuel and moderator temperatures the nominal zero power design level.

Page 8 of 11 Revision 13 North Anna Units 1 and 2

CHAPTER 1.0, USE AND APPLICATION INSERT 1 for selected In lieu of measurement, response time may be verified for verification components provided that the components and methodology have been previously reviewed and approved by the NRC.

INSERT 2 of sequential, The response time may be measured by means of any series time is measured.

overlapping, or total steps so that the entire response INSERT 3 the reactivity i10 3 With any RCCA not capable of being fully inserted, of SDM; worth of the RCCA must be accounted for in the determination and are changed to

b. In MODES 1 and 2, the fuel and moderator temperatures the nominal zero power design level.

Page 8 of 1I Revision 13 North Anna Units 1 and 2

DISCUSSION OF CHANGES CHAPTER 1.0, USE AND APPLICATION ACTIONS This change is acceptable because ITS 3.8.1, AC Sources, contains function does not exist and (verification of redundant features) to ensure that a loss of to the loss of power.

that appropriate compensatory measures will be taken to respond Chapter 5.0, Safety Similar evaluations are required by ITS LCO 3.0.6 and ITS less restrictive Function Determination Program. This change is designated as or emergency electrical because under the ITS definition the loss of either the normal declared inoperable power source for a system will not result in the system being CTS.

when that component would be considered inoperable under the L.4 The CTS Section 1.0 definitions of ENGINEERED SAFETY FEATURE TIME require RESPONSE TIME and REACTOR TRIP SYSTEM RESPONSE actuated equipment.

measurement of the response time from the sensor through the (ESF) RESPONSE The ITS definitions of ENGINEERED SAFETY FEATURE are modified to TIME and REACTOR TRIP SYSTEM (RTS) RESPONSE TIME for selected state, "In lieu of measurement, response time may be verified methodology for verification have components provided that the components and changes the CTS by been previously reviewed and approved by the NRC." This response time test.

eliminating the requirement to include all components in a response time, from The purpose of response time testing is to ensure that the system device, is consistent with measurement of a parameter to actuation of the appropriate Revision 2, "Elimination the assumptions in the safety analyses. WCAP-13632-P-A, dated January, 1996, of Pressure Sensor Response Time Testing Requirements,"

testing requirements and justified the elimination of the pressure sensor response time instead of measured.

allows the response time for selected components to be verified Channel Response WCAP-14036-P, Revision 1, "Elimination of Periodic Protection processing actuation logic Time Tests," provides the basis for using allocated signal system channel response response times in the overall verification of the protection Reports have demonstrated time. This change is acceptable because the cited Topical assurance that the systems that modified response time tests will continue to provide This change is will perform their functions as assumed in the safety analysis.

must be response time designated as less restrictive because some components which under the ITS.

tested under the CTS will not require response time testing L.5 Not used.

Page 13 Revision 13 North Anna Units 1 and 2

CHAPTER 1.0, USE AND APPLICATION CONSIDERATIONS DETERMINATION OF NO SIGNIFICANT HAZARDS 10 CFR 50.92 EVALUATION FOR LESS RESTRICTIVE CHANGES CHAPTER 1.0, CHANGE L.5 Not Used.

Page 9 Revision 13 North Anna Units 1 and 2

CHAPTER 1.0, USE AND APPLICATION Not Used.

R13 Page 10 Revision 13 North Anna Units 1 and 2

Specifications Affected: SR 3.0.3 and SR 3.0.3 Bases Description ITS license amendment.

TSTF-358, Revision 5 was included in Supplement 2 to the North Anna between Revision 5 and Revision 6 of TSTF-358 was approved by the NRC and the differences markup, and the ISTS Revision 6 are incorporated into ITS SR 3.0.3, SR 3.0.3 Bases, the ISTS Bases markup. DOC L.6 is revised to reflect the altered wording of SR 3.0.3.

SR APPLICABILITY 3.03 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified LCOs, unless conditions in the Applicability for individual Surveillance, otherwise stated in the SR. Failure to meet a performance whether such failure is experienced during the the of of the Surveillance or between performances Failure to LCO.

Surveillance, shall be failure to meet the Frequency shall perform a Surveillance within the specified in SR 3.0.3.

be failure to meet the LCO except as provided inoperable on Surveillances do not have to be performed limits.

equipment or variables outside specified of sequential, Surveillances may be performed by any series overlapping, or total steps.

SR 3.0.2 The specified Frequency for each SR is met if the the interval Surveillance is performed within 1.25 times previous specified in the Frequency, as measured from the a specified performance or as measured from the time condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "11once per . . " basis, the above Frequency extension applies to each performance after the initial performance.

the Exceptions to this Specification are stated in individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed with the within its specified Frequency, then compliancedelayed, from requirement to declare the LCO not met mayup beto the limit of the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or This delay R2 the specified Frequency, whichever is greater. the I R2 period is permitted to allow performance of for any Surveillance. A risk evaluation shall be performed R13 greater than 24 hours and the risk Surveillance delayed impact shall be managed.

delay If the Surveillance is not performed within the met, and the period, the LCO must immediately be declared not applicable Condition(s) must be entered.

(continued) 3.0-4 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

SR Applicability B 3.0 BASES SR 3.0.3 performed is the verification of conformance with the (continued) requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating to situations, or requirements of regulations (e.g., prior entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performedof when specified, SR 3.0.3 allows for the full delay period up to the specified Frequency to perform the Surveillance.

However, since there is not a time interval specified, the should be performed at the first R13 missed Surveillance reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances foras the a performance of, Surveillances that become applicable consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay not period established by SR 3.0.3 is a flexibility which is to extend intended to be used as an operational convenience limit of R2 Surveillance intervals. While-up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the missed the specified Frequency is provided to perform the Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plantorconfiguration shutting the RII changes required to perform the Surveillance any plant down to perform the Surveillance) and impact on analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This riskto impact should be R13 implement managed through the program in place 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This and Regulatory Guide addresses consideration of temporary aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and be including plant shutdown. The missed Surveillance should treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the (continued)

B 3.0-17 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 3.0.1 SRs shall be met during the MODES or other specified unless LCOs, conditions in the Applicability for individual Surveillance,

.6-- otherwise stated in the SR. Failure to meet a the performance whether such failure is experienced during p the Surveillance or between to performances of the tr-An4'~'of

.oSurveillance, shall be failure meet the LCO.' Failure to

( e"rl/-/" /perform a Surveillance within the specified Frequency shall in SR 3.0.3.

be failure to meet the LCO except as provided inoperable Surveillances do not have to be performed on limits.p/

equipment or variables outside specified J* .- SR 3.0.2 The specified Frequency for each SR is met if the the interval Surveillance is performed within 1.25 times the previous specified in the Frequency, as measured from a specified performance or as measured from the time condition of the Frequency is met.

interval For Frequencies specified as "once," the above extension does not apply.

If a Completion Time requires periodic performance on a "once per . . ." basis, the above Frequency extension performance.

applies to each performance after the initial in the Exceptions to this Specification are stated individual Specifications.

was not performed 1*J . SR 3.0.3 If it is discovered that a Surveillance compliance with the within its specified Frequency, then LCO not met may be delayed, from requirement to declare the to the limit of the time of discovery, up to 24 hours or up dela-y A rI'Sk e*t- I*o-kit, the specified Frequency, whichever is-th-NThis ra allow performance of t e

,9-pe , .. ,j Iperiod is permitted to the delay If the Surveillance is not performed within deleJ y Th*

period, the LCO must immediately be declared not met, and p A r-.o*'*J +* Ithe applicable Condition(s) must be entered.

^ . , /1 , 74l.A// / When the Surveillance is performed within the delay period immediately be and the Surveillance is not met, the LCO must (continued) 3.0-4 Rev 1, 04/07/95 WOG STS 13

SECTION 3.0, LCO AND SR APPLICABILITY INSERT 1 When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

INSERT 2 While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required to perform the Surveillance or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk of risk management action thresholds, and risk management action up to anddetermination impacts, including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

Revision 13 and 2 North Anna Units I1 and 2 Insert to Insert Page B 3.0-13 to PageB 3.0-13 Revision 13

DISCUSSION OF CHANGES SECTION 3.0, LCO AND SR APPLICABILITY L.5 CTS 4.0.2 states, "Each Surveillance Requirement shall be performed within the 25 specified surveillance interval with a maximum allowable extension not to exceed percent of the surveillance interval." ITS SR 3.0.2 states, "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as 'once,' the above interval extension does not apply. If a Completion Time requires periodic performance on a 'once per. . .' basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications." This on changes the CTS by adding, "If a Completion Time requires periodic performance a 'once per. . .' basis, the above Frequency extension applies to each performance in after the initial performance." The remaining changes to CTS 4.0.2 are discussed DOC A.10 and DOC M.2.

This change is acceptable because the 25% Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to Required Actions which must be performed periodically. The initial performance is excluded because the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Completion Time without extension in order to avoid operation in unacceptable conditions. This change is designated as less restrictive because additional time is provided to perform some periodic Actions.

L.6 CTS 4.0.3 states, in part, "The time limits of the action statement requirements are applicable at the time it is identified that a surveillance requirement has not been performed. The action statement requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the completion of the surveillance when the allowable outage time limits of the action statement requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ." ITS SR 3.0.3 states in part, "If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance *2.

of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed." This changes r? 13 to the CTS by, 1) allowing a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and up to the specified Frequency perform the missed Surveillance, provided a risk evaluation is performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and 2) basing the time allowed to perform a missed Surveillance before taking the Required Actions on the Surveillance Frequency instead of the allowed outage time The purpose of CTS 4.0.3 is to permit the delay of the ACTIONS of the LCO when a required Surveillance has not been performed, if the allowed outage time of the action is less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . For example, if the allowed outage Revision Li North Anna Units 1 and 2 Page 22 Revision 13

DISCUSSION OF CHANGES SECTION 3.0, LCO AND SR APPLICABILITY If the time is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to perform the Surveillance.

and the Action allowed outage time is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the exception does not apply to perform the is entered. In all cases, CTS 4.0.3 allows at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months met and the missed Surveillance, but requires declaring the LCO not is greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTIONS be followed if the allowed outage time met (and taking the ITS SR 3.0.3 permits the delay of declaring the LCO not Frequency of the ACTIONS) for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or up to the limit of the specified Surveillance, whichever is greater. For example, if the Surveillance Frequency is Frequency is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed. If the Surveillance must be performed 30 days, 30 days is allowed. However, a risk evaluation and the risk managed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

IQ13 Surveillance Therefore, the ITS allows additional time to perform a missed the ACTIONS to be and does not require the LCO to be declared not met and followed if a Surveillance is not performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

provides adequate This change is acceptable because this longer delay period time to complete Surveillances that have been missed while providing 92.

It is overly reasonable assurance that the subject equipment is OPERABLE.

when a conservative to assume that systems or components are inoperable of surveillance has not been performed because the vast majority are surveillances do in fact demonstrate that systems or components a question of OPERABLE. When a surveillance is missed, it is primarily of a OPERABILITY that has not been verified by the performance up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Surveillance Requirement. As stated in the ITS Bases, "While the missed or the limit of the specified Frequency is provided to perform will be performed at Surveillance, it is expected that the missed Surveillance first reasonable the first reasonable opportunity. The determination of the plant risk (from opportunity should include consideration of the impact on changes required delaying the Surveillance as well as any plant configuration in to perform the Surveillance) and impact on any analysis assumptions, and the time addition to unit conditions, planning, availability of personnel, will be required to perform the Surveillance.... All missed Surveillances the missed placed in the licensee's Corrective Action Program." Therefore, will be Surveillance will be performed at the first reasonable opportunity, under the plant evaluated for the effect on plant risk, and will be investigated requirement has no corrective action program. As a result, this less restrictive detrimental effect on unit safety.

taking the The time allowed to perform a missed Surveillance prior to and on the ACTIONS is based on the allowed outage time in CTS 4.0.3 Surveillance Frequency in ITS SR 3.0.3.

representative of This change is acceptable because the SR Frequency is more less than the safety significance of the missed SR. Surveillance Frequencies missed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are frequent, easily performed tests. Therefore, a Page 23 Revision 13 North Anna Units 1 and 2

Specifications Affected: CTS 3.3.3.1 Description Action is not dispositioned in CTS Table 3.3-6, Action 35, was marked "See ITS 3.3.3." This 1 of CTS 3.3.3.1. The CTS markup for ITS 3.3.3 and should have been relocated under DOC R.

DOC R.1.

Unit 1 and 2 is revised to delete Action 35 and reference The ITS and Bases are unaffected.

671* Z..3. (

8-2-89 TABLE 3.3-6 (Continued)

TABLE NOTATION OPERABLE requ ~ement, * '/* I required by the MiniernChannels OPERABLE less thanu Ih7e-g numbero rofea channels o h o i o e r ea ACTION 20 - With the pr ea r s 27 Z OPERABLE requie-required by the Minimum Channels e requirements l of oc ),/_

ment, comply with Specification the ACTION OPERABLE 3.4.6.1. less than rq channel With the number of ACTION 21 -

OPEEABLE comp-requirement, by the Minimum Channels met the ACTION requ opywith of irement With the number ochannels OPERABLE less than required 3,ciict6n1 ION 21 -

comply requirement, 3.92.

by thetheMinimum with annels OPERABLE Specification ACTION requtrennts-of with the ACT! requirements-of Specificat n 3.9.9.

ACTION 35- With the numb of OPERABLE channels less than r quired by the Mini m Channels OPERABLE requirement, nitiate the prepla ned alternate method of monitori the appro priate p/ ameterýs), within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and

1. ther restore the inoperable chan el(s) to OPERABLE k status within 7 days of the even , or Prepare and submit a Special eport to the

(

Commission pursuant to Spec ication 6.9.2 within 14 days following e event outlining the action ta n, the cause of the inoperability and the ans and schedule for restoring the system o OPERABLE status.

3/4 3-37 Amendment No. 64, 121 NORTH ANNA - UNIT 1

[DaJ

4ý'- TS 3, 11. 1 J

8-2-89 TABLE 3.3-6 (Continued)

TABLE NOTATION

\ if by thesurveys

~area Chnnels MinimumpeFthe OPERABLE requir, fment, perform monitored areaw*Xh portable

"* ~monitoring~istrumentation at Ileasironce =per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .j ACTION 23 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.612.l.

ACTION 24 - With the number of channels OPERABLE less than requird Jwith theMinimum ACTION Channels requi- ents of Specification OPERABLE requirement, 3. .12.

comply by the ACI - Wit the:I numberc o anel s°ERABrLElu:=essth OP reqi red/

with the ACTIO requirements of Specifica on 3.9.9.

ACTION 35 - With the num "of OPERABLE chan s less than re red by the Mini m Channels OPERABL requirement,' in iate the prepl ned alternate metho of monitoring t appro priate p ameter(s), wlthin 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , and:

1. E' her restore the in erhble channel(s atus within 7 days f the event, or to OPERABLE PI?;,

2 Prepare and submit a Special Report o the Commuission pursu t to Specificati n 6.9.2 within 14 days f llowing the eve outlining the tion taken, the auseof the inoperability nd the plans an schedule for restoring th stm to PRA Es-tautu NORTH ANNA - UNIT 2 3/4 3-40 Amendment No. 41, 106 4 0 1ý2.f /GZ-4", /3

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected: ITS 3.4.3 Description 2), dated May 2, 2001, revised the North Anna license amendment 226 (Unit 1) and 207 (Unit curves are incorporated into the Unit 1 and Unit 2 heatup and cooldown curves. The revised typed ITS, the ISTS markup, and the CTS markup.

RCS P/T Limits 3.4.3 R13 Material Property Basis Limiting Material: Circumferential Weld Seam Limiting ART at 32.3 EFPY: 1/4-T, 218.5 Deg. F 3/4-T, 195.6 Deg. F 2500.00 - - - 1 11 1 1 1

oooo ....------- -----

2000.00 ---

a._ a.t U)(n10.0 0 Unacceptable Operation x

)1000.00 . i I

,*,.. . A c c e p t a b le

,) Heatup Rates Oa (F lhr) -

40 500.00 0 50 100 150 200 250 300 350 Wide Range Cold Leg Temperature (Deg. F)

Figure 3.4.3-1 (page 1 of 1)

Unit 1 RCS Heatup Limitations first 32.3 EFPY, 1 R13 Heatup Rates up to 60 F/hr, Applicable for the 0

Including Margins for Instrumentation Errors 3.4.3-3 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

RCS P/T Limits 3.4.3 R13 Material Property Basis Limiting Material: Circumferential Weld Seam Limiting ART at 32.3 EFPY: 1/4-T, 218.5 Deg. F 3/4-T, 195.6 Deg. F 2500.00 LI _

2000.00 I

a.

S1500.00 CL

.j --- __--- Unacceptable 0 .... Operation a-0

= ... . *. -Acceptable SCooldown Rates pe ato 0

(F/hr) 500.00 20 60 100 I _F 0.00 050 100 150 200 250 300 350 Wide Range Cold Leg Temperature (Deg. F)

Figure 3.4.3-2 (page 1 of 1)

Unit 1 RCS Cooldown Limitations R13 first 32.3 EFPY, Cooldown Rates up to 1000F/hr, Applicable for the Including Margins for Instrumentation Errors 3.4.3-4 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

RCS P/T Limits 3.4.3 Basis Material Property Limiting Material: Lower Shell Plate F

Limiting ART at 34.3 EFPY: 114-T, 218.5 Deg.

314-T, 195.6 Deg. F 2500.00 -

1 .....

oooo ............_ _ _____

-Limit 2000.00 ---

0 Operation WI- 1~ 1+i IIT--

0 J I HetpRaeW Acceptable Ratt UHnt2R Operation 10 30 15 35 500.00- 100.0 6050 -----

150 Fiur 3.4.3-3 (pe 1 of 1)

-F=-P ' - 11H !-- II_ II 300 0 50 100 150 200 250 350 Wide Range Cold Leg Temperature (Deg. F)

Figure 3.4.3-3 (page 1 of 1)

Unit 2 RCS Heatup Limitations for the first 34.3 EFPY, 1R13 Heatup Rates up to 60°F/hr, Applicable Including Margins for Instrumentation Errors 3.4.3-5 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

RCS P/T Limits 3.4.3 R13 Material Property Basis Limiting Material: Lower Shell Plate Limiting ART at 34.3 EFPY: 1/4-T, 218.5 Deg. F 314-T, 195.6 Deg. F 2500.00 2000.00 --

0i I+ I C4l 1500.00 Unacceptable 0 "*~~ k Ope atio Acceptablbe

) 1000.00 "6 t _* Operatio Ix 500.00-(Flhr)

Cooldown Rates 0

20 40 7_ prto Oeaion

-- 60

__ 100 I I I .

0.00 ,'.. .. ...... .. .

100 150 200 250 300 350 0 50 Wide Range Cold Leg Temperature (Deg. F)

Figure 3.4.3-4 (page 1 of 1)

Unit 2 RCS Cooldown Limitations R13 Cooldown Rates up to 1000F/hr, Applicable for the first 34.3 EFPY, Including Margins for Instrumentation Errors 3.4.3-6 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS INSERT 1 Material Property Basis Limiting Material: Circumferential Weld Seam Limiting ART at 32.3 EFPY: 1/4-T, 218.5 Deg. F 3/4-T, 195.6 Deg. F 2500.00-Li i 2000.00-0o)

U) a u*1500.00 3"I 1 _Unacceptable g1 0 Operation G)1000.00 "cU b Acceptable Ohperr o Operation S~20 5)100.00 -- -

I - 40 0.00 0 50 100 150 200 250 300 350 Wide Range Cold Leg Temperature (Deg. F)

Figure 3.4.3-1 (page 1 of 1)

Unit 1 RCS Heatup Limitations Heatup Rates up to 60 0F/hr, Applicable for the first 32.3 EFPY, Including Margins for Instrumentation Errors Insert to Page 3.4-6 Revision 13 North Anna Units I1 and 2 Anna Units North Insert to Page 3.4-6 Revision 13

(P/T) LIMITS ITS 3.4.3, RCS PRESSURE AND TEMPERATURE INSERT 2 Material Property Basis Limiting Material: Circumferential Weld Seam Limiting ART at 32.3 EFPY: 1/4-T, 218.5 Deg. F 3/4-T, 195.6 Deg. F 2500.00 2000.00 2000.00 - - - - - - - - - -- -- - -- -

0) a)

(w

0) 1500.00 C

a- Unacceptab,,e_

0_ Operation - 7 xI ooo1o 1 d a: - Acceptable 10*Cooldown Rates Operation 00 gio~o------------------------

20 -------

500.00 604 100 0.00

300 350 0 50 100 150 200 250 Wide Range Cold Leg Temperature (Deg. F)

Figure 3.4.3-2 (page 1 of 1)

Unit 1 RCS Cooldown Limitations Cooldown Rates up to 100°F/hr, Applicable for the first 32.3 EFPY, Including Margins for Instrumentation Errors Insert to Page 3.4-6 Revision 13 North Anna Units 1 and 2

ITS 3.4.3, RCS PRESSURE AND TEMPERATURE,(P/T) LIMITS INSERT 3 Material Property Basis Limiting Material: Lower Shell Plate Limiting ART at 34.3 EFPY: 1/4-T, 218.5 Deg. F 3/4-T, 195.6 Deg. F 2500.00 1 1j--------------1-11

- - - 1-1-- - - - - - -1 1 Leak

- - - - - -- - - - - - - - - - - - - Test

--- -- -- -- - - - - - - - - - -- Limit

-H -P - 1- -1 - --- 1 -4 2000.00 - --- -- - -

L3.

u 1500.00 r0

,.! Unacceptable

,,,o Operation

0) 1000.00

-- Acceptable "HeatupRates Operation (F/hr) 20 40 500.00 0.00 ~-. - - - - - - .-.-.

a ll - - --

0 50 100 150 200 250 300 350 Wide Range Cold Leg Temperature (Deg. F)

Figure 3.4.3-3 (page 1 of 1)

Unit 2 RCS Heatup Limitations Heatup Rates up to 60°F/hr, Applicable for the first 34.3 EFPY, Including Margins for Instrumentation Errors and 22 Insert to Page 3.4-6 North Anna Units I1 and Insert to Page 3.4-6 Kevislon 13

ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS INSERT 4 Material Property Basis Limiting Material: Lower Shell Plate Limiting ART at 34.3 EFPY: 1/4-T, 218.5 Deg. F 3/4-T, 195.6 Deg. F 2500.00 2000.00 0.

6) to 1500.00 U)

- Unacceptable 0~

U) Operation

)1000.00

- - Acceptable c)

Cooldown Rates -- Operation

_ (F/hr) +

0 500.00 20 -a 40

-- 60 100 0.0(0LifhifAIL 0 50 100 150 200 250 300

-A 350 Wide Range Cold Leg Temperature (Deg. F)

Figure 3.4.3-4 (page 1 of 1)

Unit 2 RCS Cooldown Limitations Cooldown Rates up to 100 F/hr, Applicable for the first 34.3 EFPY, 0

Including Margins for Instrumentation Errors Insert to Page 3.4-6 Revision 13 North Anna Units 1 and 2

-T.73 -ý,41,3 A

6Z ?ýZ Figure 3.4-2 North Anna Unit 1 Reactor Coolant System Heatup Limitations Material Property Basis Limiting ART at 32.3 EFPY: 1/4-T, 218.5 deg. F 3/4-T, 195.6 deg. F 2500.00 2000.00 S1500.00 4) 0 "1

S1000.00 "4) 500.00 0.00 50 100 150 200 250 300 350 0

Wide Range Cold Leg Temperature (Deg. F)

Rates up to 60 F/hr)

North Anna Unit 1 Reactor Coolant System Heatup Limitations (Heatup Margins for Instrumentation Errors)

Applicable for the first 32.3 EFPY (Including 3/4 4-27 Amendment No. 16,74, 117,170, NORTH ANNA - UNIT I /,p j3 -899 226

05-02-01 32 4e Figure 3.4-3 North Anna Unit 1 Reactor Coolant System Cooldown Limitations Material Property .Basis Limiting ART at 32.3 EFPY: 1/4-T, 218.5 deg. F 3/4-T, 195.6 deg. F 2500.00 r 1K r1k 2000.00 NE, gk, 72- WON T1111 NOT,:

Cn a)

I-S1500.00 Cn R WE IL Pm CM a) I& Z; mi

'g S1000.00 n,

3r

-pe 24 P91f 500.00

.. -I

'14 "N

INI 4- ' z

' I~ *3.r 0.00 350 50 100 150 200 250 300 0

Wide Range Cold Leg Temperature (Deg. F) up to 100 F/hr)

North Anna Unit 1 Reactor Coolant System Cooldown Limitations (Cooldown Rates Applicable for the first 32.3 EFPY (Including Margins for Instrumentation Errors) 3/4 4-28 Amendment No. 16,74,117, 170, NORTH ANNA - UNIT 1 41V 1' 4-89, 226

/O6Za 3ý f 3

ý7-/ý J, 'f,-3 3 -- 3 Figure 3.4-2 North Anna Unit 2 Reactor Coolant System Heatup Limitations Material Property Basis Limiting ART at 34.3 EFPY: 1/4-T, 218.5 deg. F 314-T, 195.6 deg. F 2500.00 2000.00 Ur)

En o)

I.

""1500.00 U) cm 0) 0,1 "I

a) 1000.00 C,

500.00 0.00 200 250 300 350 0 50 100 150 Wide Range Cold Leg Temperature (Deg. F)

Rates up to 60 F/hr)

North Anna Unit 2 Reactor Coolant System Heatup Limitations (Heatup Applicable for the first 34.3 EFPY (Including Margins for Instrumentation Errors) 3/4 4-27 Amendmenty'4},No. 600-41,

.% I207 f*-O NORTH ANNA - UNIT 2 o2

-/7> 05-02-01 Figure 3.4-3 North Anna Unit 2 Reactor Coolant System Cooldown Limitations Material Property Basis Limiting ART at 34.3 EFPY: 1/4-T, 218.5 deg. F 3/4-T, 195.6 deg. F 2500.00 2000.00 2M S1500.00

(.

_1 0

0 "t

01000.00

"(V 500.00 0.00 150 200 250 300 350 0 50 100 Wide Range Cold Leg Temperature (Deg. F)

(Cooldown Rates up to 100 F/hr)

North Anna Unit 2 Reactor Coolant System Cooldown Limitations Applicable for the first 34.3 EFPY (Including Margins for Instrumentation Errors) 3/44-28 Amendment No. 619,-49,r14, NORTH ANNA - UNIT 2 . l3 207 3,Oc "f

Specifications Affected: ITS 3.4.3, 3.4.8, 3.4.12, and 3.4.18 Description lists by ITS LCOs 3.4.3, 3.4.8, 3.4.12, and 3.4.18 are revised to follow the punctuation rules for adding semicolons and conjunctions as described in NEI 01-03, "Writer's Guide for the markup are Improved Standard Technical Specifications," Section 2.1.3.c. The ITS and ISTS affected.

RCS P/T Limits 3.4.3 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.3 RCS Pressure and Temperature (P/T) Limits and cooldown LCO 3.4.3 RCS pressure, RCS temperature, and RCS heatupspecified in rates shall be maintained within the limits Figures 3.4.3-3 Figures 3.4.3-1 and 3.4.3-2 (Unit 1) and and 3.4.3-4 (Unit 2) with:

period;

a. A maximum heatup of 60°F in any one hour

b. A maximum cooldown of lO0°F in any one hour period; and t R13 in any one hour period

c. A maximum temperature change of 10OF testing operations during inservice hydrostatic and leakcurves.

above the heatup and cooldown limit APPLICABILITY: At all times.

ACTIONS REQUIRED ACTION COMPLETION TIME CONDITION 30 mnue A.1 Restore parameter(s) 30 minutes A. --------- NOTE -------- to within limits.

Required Action A.2 shall be completed whenever this AND Condition is entered. A.2 Determine RCS is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

acceptable for continued operation.

Requirements of LCO not met in MODE 1, 2, 3, or 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. Required Action and associated Completion AMn Time OT Conaition A not met. r,,__

B.2 Be in MODE 5 with RCS 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months pressure < 500 psig.

3.4.3-1 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

RCS Loops-MODE 5, Loops Not Filled 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops-MODE 5, Loops Not Filled LCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

R13

- - - - - - - - - - -NOTES RAI

1. All RHR pumps may be removed from operation for 3.9.5.-1 R4

15 minutes when switching from one loop to another provided:

a. The core outlet temperature is maintained > 10'F below R13 saturation temperature;

b. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1; and

c. No draining operations to further reduce the RCS water volume are permitted.

2. One RHR loop may be inoperable for

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

APPLICABILITY: MODE 5 with RCS loops not filled.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.1 Initiate action to Immediately A. One required RHR loop restore RHR loop to inoperable.

OPERABLE status.

3.4.8-1 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

LTOP System 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP) System LCO 3.4.12 An LTOP System shall be OPERABLE with a maximum of one charging pump and one low head safety injection (LHSI) pump capable of injecting into the RCS and the accumulators isolated, with power removed from the isolation valve ~RAI operators, and one of the following pressure relief I3.4-12 RI capabilities:

a. Two power operated relief valves (PORVs) with lift settings of:

1.

500 psig (Unit 1), 415 psig (Unit 2) when any RCS cold R13 0

leg temperature 5235 F (Unit 1), 270°F (Unit 2); and

2.

395 psig (Unit 1), 375 psig (Unit 2) when any RCS cold R13 leg temperature *150°F (Unit 1), 130'F (Unit 2).

b. The RCS depressurized and an RCS vent of Ž 2.07 square inches.

NOTES-- - ----------

1. Two charging pumps may be made capable of injecting for

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for pump swapping operations.

2. Accumulator isolation with power removed from the isolation valve operators is only required when accumulator pressure is greater than the PORV lift setting.

MODE 4 when any RCS cold leg temperature is

235 0 F (Unit 1),

APPLICABILITY:

270°F (Unit 2),

MODE 5, MODE 6 when the reactor vessel head is on.

ArTTnMhK

IIU I

CONDITION REQUIRED ACTION COMPLETION TIME I _ _ _ _ _ _ _ _ _ _ i A.1 Initiate action to Immediately A. Two LHSI pumps capable verify a maximum of of injecting into the one LHSI pump is RCS.

capable of injecting into the RCS.

I ________________________ -p______________

3.4.12-1 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

RCS Isolated Loop Startup 3.4.18 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.18 RCS Isolated Loop Startup both loop LCO 3.4.18 Each RCS isolated loop shall remain isolated with valve isolation valves closed and power removed from the operators unless:

a. The isolated loop is filled and:

the

1. The boron concentration of the isolated loop is ' 3.1.1 boron concentration required to meet SDM of LCO or the boron concentration of LCO 3.9.1 prior to R13 opening the hot leg isolation valve;

2. The hot leg isolation valve has been open with minutes recirculation line flow of Ž 125 gpm for Ž 90 prior to opening the cold leg isolation valve; and

20°F

3. The cold leg temperature of the isolated loop is below the highest cold leg temperature of the operating or loops prior to opening the cold leg isolation valve;

b. The isolated loop is drained and:

- - - - - - - - --- ---- NOTE -----

Seal injection may be initiated to the RCP in the of the isolated, drained loop and continued during filling isolated loop from the active RCS volume provided:

1) The isolated loop is initially drained; and

2) The boron concentration of the seal injection source is : the boron concentration required to meet the SDM of LCO 3.1.1 or the boron concentration of LCO 3.9.1.

prior to

1. Pressurizer water level is maintained Ž 32%

the hot or cold leg isolation and during the opening of valves; and open

2. The hot and cold leg isolation valves are fully within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after the loop is filled.

3.4.18-1 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS INSERT

2) with:

Figures 3.4.3-1 and 3.4.3-2 (Unit 1) and Figures 3.4.3-3 and 3.4.3-4 (Unit

a. A maximum heatup of 60OF in any one hour period; A maximum cooldown of 100°F in any one hour period; and I* ,

b.

during inservice

c. A maximum temperature change of 10°F in any one hour period limit curves.

hydrostatic and leak testing operations above the heatup and cooldown Insert to Page 3.4-5 Revision 13 North Anna Units 1 and 2

RCS Loops-MODE 5. Loops Not Filled 3.4.8 CA5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops-MODE 5. Loops Not Filled LCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

............................... ,- NOTES ........................... 7R14D reieio f i. Al1 RHR pumps may bee-er i for 5 15 minutes when from one loop o anot r provided:

Sswitching

a. (the core outlet temperature is maintained > 10F /Ply low saturation temperaturea

.rations rpe ermitted/that woulddatse T~s r-ion 7 4he RCS boran concentrat.idn' : Vd

c. No draining operations to further reduce the RCS water volume are permitted.

'j, One RHR loop may be inoperable for 5 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

s-2

/es~

L~O3,1.)a, APPLICABILITY: MODE 5 with RCS loops not filled.

ArTTAW*

LCUNDIUIION REQUIRED ACTION COMPLETION TIME

-S7-/-TF-) 63 A. One RHR loo A.I Initiate action to Immediately inoperable. restore RHR loop to OPERABLE status.

______________________ I I (continued)

WOG STS 3.4-17 Rev 1. 04/07/95 S13

LTOP System 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP) System LCO L.6c 3.53

,co 3.9'3 valves witysetpoints > [43, 1 psig and

[2 : wo[463. psig. ator]removal (RH residual suction relie (

[3. One -- RV with a li ft etting within limits T7; -i--28, I.

s cified~in the PR and one RHR ction relie l alIve with a se int ;-[436.5] *g a,,nd "

_.L_ -s [463.5] psi_, r-"

AfgIdc4 t b. The RCS depressurized and an RCS vent of -_- .0 square inches. -,3 -*s -*74 APPLICABILITY: MODE 4 whena RCS cold leg temperature is 5 2 MODE 5, 3 MODE 56when_thýe cjtor vesel head is on.

oisolation sonl re uired when accumulator prres S greater than or equa t, maxiip re~ssb P~i o mit exis 1uthe cu #s ng RCS cof in,let6eIi..

proi- terne ue&roe .... -- *]/

. . P.. . . . .. . e-- . . .. .. .... ... ... S 2z.. 6L/a 7l,i,2), -'42) waher

/ 30 OFf-iU1r42-)

WOG STS 3.4-27 Rev 1. 04/07/95

TRAI 4/ 9 1a.13

ITS 3.4.18, RCS ISOLATED LOOP STARTUP INSERT 1 LCO 3.4.18 Each RCS isolated loop shall remain isolated with both loop isolation S75* 3. ý" t,5* valves closed and power removed from the isolation valve operators unless:

q',1,6

a. The isolated loop is filled and:

3, j 1. The boron concentration of the isolated loop is > the boron concentration required to meet the SDM of LCO 3.1.1 or the boron concentration of LCO 3.9.1 prior to Id '3 opening the hot leg isolation valve; ap4d.Y L(.0 2. The hot leg isolation valve has been open with recirculation line flow of > 125 gpm for > 90 minutes prior to opening the cold leg isolation valve; and L(-o

?. 61 hsq 3. The cold leg temperature of the isolated loop is > 20°F below the highest cold leg temperature of the operating loops prior to opening the cold leg isolation valve; or

b. The isolated loop is drained and:

NO T E S ---------------------------------------

Seal injection may be initiated to the RCP in the isolated, drained loop and continued during filling of the isolated loop Le,.D 2)..W I,t .-0' from the active RCS volume provided:

1) The isolated loop is initially drained; and

2) The boron concentration of the seal injection source is

> the boron concentration required to meet the SDM of LCO 3.1.1 or the boron concentration of LCO 3.9.1.

1. Pressurizer water level is maintained > 32% prior to 3, .4, 2 cL( and during the opening of the hot or cold leg isolation valves; and

2. The hot and cold leg isolation valves are fully open O Z '-.* 2.

within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after the loop is filled.

N O T-------------------------------.

E ------------------------------------------

A hot or cold leg isolation valve may be closed for up to two hours for valve maintenance or testing. If the isolation valve is not opened within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the loop shall be isolated.

Insert to Page 3.4-49 Revision 13 North Anna Units 1 and 2

Specifications Affected: ITS 3.4.6, 3.4.7, and 3.4.8 CTS markup and DOCs Description CTS Surveillance 4.4.1.3.2 requires verification of correct breaker alignment and indicated power availability for required reactor coolant pumps not in operation. ITS Surveillances power 3.4.6.3, 3.4.7.3, and 3.4.8.2 require verification of correct breaker alignment and indicated availability for reactor coolant pumps and residual heat removal pumps not in operation. This difference was not addressed in the submittal. The CTS markup for ITS 3.4.6, 3.4.7, and 3.4.8 is revised and DOC M.3 is added to ITS 3.4.6 and ITS 3.4.8, and DOC M.4 is added to ITS 3.4.7 to address the change.

The ITS and ITS Bases are unaffected.

Lk. L10 8-27-90 RFACTOR COOLANT SYSTEM A.b SHUTDOWNN I SURVEILLANCE REQUIREMENTS S'URVEIILLANCE REQUIREMENTS 4.4.1.3.1 The quired RHR ubsystems sh 4_____.. ___/_ _ 4/ D be demons mied OPERABIE per yCArL 4.4.1.3.2 The requird act oolhnt uip(s). not In peration, shall be determined to be OPERABLE once per 7 days ying correct breaker alignment and indicated power availability.

4.4.1.3.3 The required steam generator(s) shall be determined OPERABLE by verifying S?R Lf.ý 2 secondary side water level to be greater than or equal to 17% at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

',p 3,q,6.

4.4.1.3.4 At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , verify at least one coolant loop to be in operatioik __o Z-A 2

a. Verifying at least one Reactor Coolant Pump is in operation.

or

b. Verifying at least one RHR Loop is in operation

. i t hCS temperatu 0

>n r4aFor the A

<.I hours. circ R nreactor cootdiita NORTH ANNA - UNIT 1 3/4 4-3a Amendment No. -2 137 1 c-c 2 i2

/

z-s 04/ 8-27-90 REACTOR COOLANT SYSTEM I

URVMAN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The requ RHR subs shall be onstrated OP Spe& tion 4.7.9.1,1 0.

The requiredreci ol pum s, not in-operauion, sh determined to be 4.4.1.3.2 OPERABLE once per 7 days by verify.ng correct breaker alignment and indicated power availability.

S4.4.1.3.3 The required steam generator(s) shall be determined OPERABLE by verifying per 12 secondary side water level to be greater than or equal to 17% at least once hours.

u b 4.4.1.3.4 At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , verify at least one coolant loop to be in operationja'Z

(ýý+/-#!eaMWgr _oojafii Y:

a. Verifying at least one Reactor Coolant Pump is in operation.

b.

or Verifying at least one RHR Loop is in operatio aid. "

thýme since nt.....

entry -rt6MODE 3 is 1(0;3 S1. ifIe'RCS temperaturo,7 140F

< 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , circulatng reactor coolant at a flow rate Z,3000 gpm.

MOD/ i or

2. if the RCS/temperature < 140 F and the time since entry into MO a-ie:"

- > 100h6"urs, circulating refictor coolant at a flow rate a 2000 gpm to-emove j de/y heat. . . ................

.2* ........... ....... ....... ........... "

3/4 4-3a Amendment No. 120 NORTH ANNA - UNIT 2

DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 stratification and to perform the cooldown. Requiring immediate actions to avoid boron change is designated as more restore a loop to OPERABLE status are appropriate. This concentration reductions restrictive because is requires immediate action stop RCS boron a cooldown.

in a condition for which the CTS allows 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months prior to completing and at least one M.2 CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE that states that all reactor must be in operation. This requirement is modified by a note in operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

coolant pumps and residual heat removal pumps may not be the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months exception to once ITS 3.4.6 contains the same allowance, but limits the use of per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

of certain infrequent The purpose of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance is to allow the performance change is acceptable because startup tests which require coolant flow to be stopped. This removal do not occur should it ensures that boron stratification or inadequate decay heat This change is designated as multiple 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months periods be required to complete the tests.

8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period when that more restrictive because it limits an allowance to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per restriction does not currently exist.

if not in operation, shall be M.3 CTS 4.4.1.3.2 states that the required reactor coolant pump(s),

and indicated power determined OPERABLE by verifying correct breaker alignment breaker alignment and availability. ITS SR 3.4.6.3 requires verification that correct operation. LCO 3.4.6 allows a indicated power are available to the required pump not in changes the CTS by combination of reactor coolant pumps and RHR pumps. This indicated power availability on requiring verification of correct breaker alignment and required RHR pumps which are not in operation.

to provide RCS cooling The purpose of the CTS is to ensure a standby pump is available because the verification of should the operating pump fail. This change is acceptable an additional RCS or RHR proper breaker alignment and power availability ensures that decay heat removal and reactor pump can be placed in operation, if needed, to maintain because it requires coolant circulation. This change is designated as more restrictive to reactor coolant pumps.

performance of the Surveillance on RHR pumps in addition RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES Description,Including Design LA.1 (Type 1 - Removing Details of System Design and System of any combination of RCS Limits) CTS 3.4.1.3 states that two coolant loops consisting a description of what constitutes loops and RHR loops shall be OPERABLE and contains loop. ITS 3.4.5 an OPERABLE Reactor Coolant loop and Residual Heat Removal Page 2 Revision 13 North Anna Units 1 and 2

TJSt A.1 8-27-90 wis I The requiredf aREc coolp-rj

I?-3? q -7,3 OPERABLE once per 7 days power availability. "(7T .SI4 3,'.

The required steam generator(s) shall be determined OPERABLE by verifying 54' >i.Th2 secondary side water level to be greater than or equal to 17% at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . (; 5fl upl p 4.4.1.3.4 At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , vercql.hint'doop to be in operation*o e

"a. exifyxg at leasx-4 e Reactor-°Co J t Pump is in ope/ra**on- (-LI or

b. Verifyinj t neRHR Loop is in operation 5d-"\

1/1. - the RCS temperatre > 140'F or theue since entryjnt

< 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , circilating reactor coirat at a flow r='4 30 0

NORTH ANNA - UNIT I 3/4 4-3a Amendment No. -2 137 7 -t X44P

/

-r_C-5 8-27-90 REACTOR COOLANT SYSTEM D/4/

I SURVEILLANCE REQUIREMENTS 41

,'Ltot in opercion, shall be determined to be 31A'o

A~L1, 73 OPERABLE once per 7 days by verifying correct breaker alignment and indicated poweravailability.( ._s,* ,- poi c, */? p".7"3 *'o/

4.4.1.3.3 The required steam generator(s) shall be determined OPERABLE by verifying A,qZ

-e secondary side water level to be greater than or equal to 17% at least once per 12 LI.

hours. ond pe 12 h u s -r4 0

/i-..,*,.( 4.4.1.3.4 At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , verify e or c loop to be in operatiorr$)

)

or aCe b Verfyig tI n RHR Loop is in operation/

1. iRCS tenmpera > 14O0 F =the ' e since entry intzoMQDE 3is

< 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , circ ating reactor cool t at a flow rate 2:3000 gpm.

or t2. if the R temperature* 140' and the time sin entry into MODE is I ours. circulating reac r coolant at a flowrate >2000 gpm toremove de y heat.

NORTH ANNA - UNIT 2 3/4 4-3a Amendment No. 120 Q2cr.e I Ir3

//

DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED are M.2 CTS 3.4.1.3, Action a, states that when less than the two required coolant loops OPERABLE OPERABLE, immediate action must be taken to return the required loops to within 20 hours. CTS status as soon as possible and the unit must be in cold shutdown 3.4.1.3, Action b , states that when no coolant loops are in operation, all operations and action involving a reduction in boron concentration of the RCS must be suspended Action A must be initiated to return the required coolant loop to operation. 'ITS 3.4.7, is OPERABLE or applies when one required RHR loop is inoperable and one RHR loop limits and one when the required steam generator secondary side water level is not within or steam RHR loop is OPERABLE and requires immediate action to restore the RHR SG secondary side water generator. ITS 3.4.7, Action B states that when the required taken to level is not within limit and one RHR loop is OPERABLE, action must be the SG secondary side restore a second RHR loop to OPERABLE status or to restore RHR R13 states that if no required water level within limit immediately. ITS 3.4.7, Action C, suspend all loops are OPERABLE or if the required RHR loop is not in operation, concentration operations that would cause introduction into the RCS, coolant with boron initiated to less than required to meet SDM of LCO 3.1.1 and action must be immediately the CTS by restore one RHR loop to OPERABLE status and operation. This changes change in the revising the actions to be taken if both RHR loops are inoperable. The of action from suspending reductions in boron concentration to suspending introduction is described in coolant with a boron concentration less than required to meet LCO 3.1.1 DOC L.4.

of one or This change is acceptable because it provides appropriate actions for a loss loops are inoperable, suspending lei'?

more required RHR loops or SG. If both required RHR because all operations involving a reduction of RCS boron concentration is appropriate change is all forced flow used to ensure proper mixing of RCS boron is lost. This action to the CTS.

designated as more restrictive because it adds an additional and at least one M.3 CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE that all reactor must be in operation. This requirement is modified by a note that states for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

coolant pumps and residual heat removal pumps may be de-energized the use of the 1 ITS 3.4.7 also allows the RHR pumps to be stopped for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , but limits hour exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

certain infrequent The purpose of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance is to allow the performance of acceptable because startup tests which require coolant flow to be stopped. This change is do not occur should it ensures that boron stratification or inadequate decay heat removal is designated as multiple 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months periods be required to complete the tests. This change period when that more restrictive because it limits an allowance to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months restriction does not currently exist.

in operation, shall be CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not M.4 determined OPERABLE by verifying correct breaker alignment and indicated power g1 alignment and availability. ITS SR 3.4.7.3 requires verification that correct breaker This changes indicated power are available to the required RHR pump not in operation.

Page 3 Revision 13 North Anna Units 1 and 2

DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED indicated power the CTS by requiring verification of correct breaker alignment and availability on required RHR pumps which are not in operation.

is available to provide RCS cooling P 13 The purpose of the CTS is to ensure a standby pump the verification of should the operating pump fail. This change is acceptable because additional RHR pump proper breaker alignment and power availability ensures that an and reactor coolant can be placed in operation, if needed, to maintain decay heat removal requires performance circulation. This change is designated as more restrictive because it pumps.

of the Surveillance on RHR pumps in addition to reactor coolant RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES CTS Surveillance 4.4.1.3.4 LA. 1 (Type 3 - Removing ProceduralDetailsfor Meeting TS) be verified to be in states that at least one Reactor Coolant pump or RUR loop shall ITS SR 3.4.7.1 states operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

This changes the that an RHR loop shall be verified to be in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

circulating reactor coolant CTS by moving the requirement to verify that the RHR loop is L.1.

to the Bases. Other related changes are described in LA.3 and from the Technical The removal of this detail for performing Surveillance Requirements not necessary to be in the Specifications is acceptable because this type of information is of the public health and Technical Specifications in order to provide adequate protection loop be in operation, and a safety. The ITS retains the requirement that a reactor coolant described in the ITS loop that is in operation will be circulating reactor coolant. As flow rate, Bases, verification that a reactor coolant loop is in operation includes acceptable because these temperature, or pump status monitoring. Also, this change is ITS Bases. This change is types of procedural details will be adequately controlled in the procedural details for designated as a less restrictive removal of detail change because form the Technical meeting Technical Specification requirements are being removed Specifications.

CTS Surveillance LA.2 (Type 3 - Removing ProceduralDetailsfor Meeting TS Requirements) that one RIR loop is 4.4.1.3.4.b states that at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months it must be verified dependent on RCS in operation. It goes on to provide minimum RHR flow rates 3.4.7.1 requires temperature or time since entry into MODE 3. ITS Surveillance This changes the CTS by verification that one RHR loop is in operation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Requirements Manual.

moving the RHR minimum flow requirements to the Technical from the Technical The removal of these details for performing surveillance requirements is not necessary to be Specifications is acceptable because this type of information Page 4 Revision 13 North Anna Units 1 and 2

8-2TS 8-27-90 REACTOR COOLANT SYSTEM AJ I

SURVEILLANCE REQUIREMENTS 4.4.1.3.1 /_The red RHRs stems shall b monstated OPE LEper ification 4.7 . _---*/, 1 4.4.1.3.2 The required acpt)

OPERABLE once per 7 days by verifying correct breaker ainent and indtated .

power availability. Oe,,- $4' 3/. .2 j1eg 4.4.1.3.3 The 'd stea generat s) shall be dete ed OPERAB y verif (AD2 se l side waterle to be greater or equal to 17 atleast on r 12 4.4.1.3.4 At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , verifyja-loop to be in operatione ) Z*4 /

a. Ve<, "ngatle one Reafrool mpis raion.

c@)

b. Verifying at least one RJi Loop is in operat I. if* the RC" temperature A40°F or the

<lOO'hours. circulatin reactor coolaz 2.

NORTH ANNA - UNIT 1 3/4 4-3a Amendment No. ;Q; 137 2

/?a/1?

?cz7e

/ j

8-27-90 REACTOR COOLANT SYSTEM (D I

I4lD 4.4.1.3.2 The requiredt2E fc .ý2t)pump(s), if not in operation, shail be aetermmnco to oe L}. Z OPERABLE once per 7 days by verifying correct breaker alignment and indicated power availability. (2rIS e r'.eo" SW 3 26.51 Fz 4.4.1.3.3 11 he reuire6 steam generator(s) shall be dete iiWed OPERABLEh~verifying se:oadary side wamreevel to be greater* or equal %-7-at least onc, 1 Xr2

ý h ours . - . .. . . -

4.4.1.3.4 At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a iyloop to be in operatior"

>'K 3'i f actoror by:

a. 1of* -'co es on

, u*¢*

(A2

b. Verifying at least one RHR Loop is in opei 0 co ator40

1. if theoRC§temperature

< 1O0'ours. circulatin imactor coc NORTH ANNA - UNIT 2 3/4 4-3a Amendment No. 120 13 aye2 of .2-~~

DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED to ensure proper RCS boron concentration is appropriate because all forced flow used because it mixing of RCS boron is lost. This change is designated as more restrictive adds an additional action to the CTS.

pumps to be de M.2 CTS 3.4.1.3 contains an allowance for all reactor coolant pumps or RHR from [ t~"

energized for up to one hour. ITS 3.4.8 allows all RHR pumps to be removed only and also requires operation for<* 15 minutes for switching from one loop to the other are permitted.

that no draining operations to further reduce the RCS water volume to perform loop This change is acceptable because the Note provides sufficient time tests performed using switching operations and provide adequate controls. The startup performed with the the CTS Note allowance in MODE 4 or 5 with loops filled are not those tests are not RCS loops not filled. Therefore, the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance for performing the RCS is not filled needed in this condition. Stopping all operating RIiR loops when inventory of water should be limited to short periods of time because of the reduced swapping available to absorb decay heat. Stopping all RHR pumps during loop occur if both pumps are operations is necessary to ensure that pump vortexing does not the loop swapping run simultaneously. Fifteen minutes is sufficient time to perform due to lack of decay operation without excessive increases in RCS average temperature operations be performed heat removal. Adding the additional condition that no draining level and the when the pumps are stopped is reasonable given the low RCS water if needed.

unavailability of the RHR pumps to add inventory to the RCS if not in operation, shall be M.3 CTS 4.4.1.3.2 states that the required reactor coolant pump(s),

and indicated power determined OPERABLE by verifying correct breaker alignment alignment and availability. ITS SR 3.4.8.3 requires verification that correct breaker in operation. This changes indicated power are available to the required RHR pump not and indicated power the CTS by requiring verification of correct breaker alignment availability on required RHR pumps which are not in operation.

provide RCS cooling The purpose of the CTS is to ensure a standby pump is available to the verification of should the operating pump fail. This change is acceptable because an additional RHR pump proper breaker alignment and power availability ensures that and reactor coolant can be placed in operation, if needed, to maintain decay heat removal it requires performance circulation. This change is designated as more restrictive because pumps.

of the Surveillance on RIR pumps in addition to reactor coolant RELOCATED SPECIFICATIONS None Page 3 Revision 13 North Anna Units 1 and 2

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected: ITS 3.4.7 and ITS 3.4.7 Bases Description loop be OPERABLE with ITS LCO 3.4.7 requires two RHR loops be OPERABLE or one RUR Condition B states "One or the secondary side water level of one Steam Generator (SG) > 17%.

to restore required SGs.

more required SGs" and Required Actions A.2 and B.2 require action Actions A.2 and B.2 is The reference to more than one required SG in Condition B and Required B.2 are revised to refer inconsistent with the LCO. Condition B and Required Actions A.2 and change affects ITS 3.4.7, the to a single required SG. The ACTION Bases are also revised. This M.2 is revised to reflect ITS 3.4.7 Bases, the ISTS markup, and the ISTS Bases markup. DOC the new ACTION wording.

RCS Loops-MODE 5, Loops Filled 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR loop A.1 Initiate action to Immediately inoperable, restore a second RHR loop to OPERABLE Arn status.

One RHR loop OPERABLE. OR A.2 Initiate action to Immediately RAI R 1 3.4-22 restore required SG R13 secondary side water R1RAI3.4-22 level to within limits.

Immediately R13 B.1 Initiate action to B. Required SG with restore a second RHR secondary side water loop to OPERABLE RAI 3.4-22 level not within status.

limits.

OR AND Initiate action to Immediately One RHR loop OPERABLE. B.2 RAI 3.4-22 restore required SG Ri R13 secondary side water level to within limits.

C. No required RHR loops C.1 Suspend operations Immediately OPERABLE. that would cause introduction into the OR RCS, coolant with boron concentration Required RHR loop not less than required to in operation. meet SDM of LCO 3.1.1. R1 AND C.2 Initiate action to Immediately restore one RHR loop to OPERABLE status and operation.

3.4.7-2 Rev 13 (Draft 2), 01/25/02 North Anna Units 1 and 2

RCS Loops-MODE 5, Loops Filled B 3.4.7 BASES APPLICABILITY In MODE 5 with the unisolated portion of the RCS loops filled, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of RHR provides sufficient RHR circulation for these purposes. However, one additionalwater side loop is required to be OPERABLE, or the secondary with the level of at least one SG is required to be ' 17%

associated loop isolation valves open.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

If all RCS loops are isolated, an SG cannot be used for decay heat removal and RCS water inventory is substantially reduced. In this circumstance, LCO 3.4.8 applies.

ACTIONS A.1, A.2, B.1, and B.2 lR11 the required SG has secondary If one RHR loop is OPERABLE and is lost.

side water level < 17%, redundancy for heat removal RHR to restore a second Action must be initiated immediately SG loop to OPERABLE status or to restore the required will secondary side water level. Either Required Action restore redundant heat removal paths. The immediate the Completion Time reflects the importance of maintaining availability of two paths for heat removal.

C.1 and C.2 except during I3422 If a required RHR loop is not in operation, or if no required RI 4,

conditions permitted by Note 1 and Note introduction RHR loop is OPERABLE, all operations involving RCS with boron concentration less than of coolant into the must be required to meet the minimum SDM of LCO 3.1.1 to restore one RHR loop to OPERABLE suspended and action must be initiated. Suspending the status and operation into the RCS of coolant with boron introduction of coolant required to meet the minimum SDM of concentration less than (continued)

B 3.4.7-4 Rev 13 (Draft 2), 01/25/02 North Anna Units 1 and 2

ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED INSERT A. One required RHR loop A.1 Initiate action to restore a Immediately second RHR loop to inoperable.

OPERABLE'status.

AND OR One RHR loop A.2 Initiate action to restore Immediately OPERABLE. "

required SGjsecondary 03 0Iea side water level to within limits.

I I-Immediately 1)

Iea3 B. (0ýmoreyequired B.1 Initiate action to restore a second RHR loop to with secondary side OPERABLE status.

water level not within limits.

OR AND Immediately B.2 Initiate action to restore One RHR loop required SC-secondary side water level to within OPERABLE.

limits.

Insert to Page 3.4-15 Revision 13 North Anna Units I and 2

1f RCS Loops-MODE 5. Loops BFilled 3.4.7 BASES or the secondary side water level of at least*gIjSG&is 0

APPLICABILITY ontinued) required to be >(:170

/?C-s /l/j/, Operation in other MODES is covered by: t

.k- LCO 3.4.4. "RCS Loops-MODES 1 and 2";

..1 irn 'a A r, "Orr, I 'nnns-MODl 3"!

LCO 3.4.6, "RCS Loops-MODE 4":

ACe TO LCO 3.4.". "RCS Loops-MODE 5, Loops Not Filled":

LCO 3.9.5. "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6): and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6). (V rlý ACTIONS A.1( AA0 If one RHR loop is'6Ian~ Vthe required SG(i .&

secondary side water levelV < L17* , redundancy for heatto removal is lost. Action must be initiated immediately restore a second RHR loop to OPERABLE status or to restore the required SG condary side water levelg. Either Required Action e A.2 will restore redundant heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

IfQNHR loop iswiD/operatic permitted by Note 1, or if nc operations involving 4 must be suspended and action OPERABLE status and o2peratior pro..er'miixing an eserve ti eof ra

n nhei t teimii~portance o maintainini (continued)

Rev 1. 04/07/95 WOG STS B 3.4-35

,13

DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED loops are M.2 CTS 3.4.1.3, Action a, states that when less than the two required coolant OPERABLE, immediate action must be taken to return the required loops to OPERABLE 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . CTS status as soon as possible and the unit must be in cold shutdown within operations 3.4.1.3, Action b , states that when no coolant loops are in operation, all must be suspended and action involving a reduction in boron concentration of the RCS Action A must be initiated to return the required coolant loop to operation. ITS 3.4.7, loop is OPERABLE or applies when one required RHR loop is inoperable and one RHR limits and one when the required steam generator secondary side water level is not within RHR or steam RHR loop is OPERABLE and requires immediate action to restore the side water generator. ITS 3.4.7, Action B states that when the required SG secondary taken to level is not within limit and one RHR loop is OPERABLE, action must be side restore a second RIR loop to OPERABLE status or to restore the SG secondary required RHR R13 water level within limit immediately. ITS 3.4.7, Action C, states that if no suspend all loops are OPERABLE or if the required RIR loop is not in operation, concentration operations that would cause introduction into the RCS, coolant with boron be immediately initiated to less than required to meet SDM of LCO 3.1.1 and action must the CTS by restore one RIR loop to OPERABLE status and operation. This changes The change in the revising the actions to be taken if both RIR loops are inoperable.

introduction of action from suspending reductions in boron concentration to suspending 3.1.1 is described in coolant with a boron concentration less than required to meet LCO DOC L.4.

of one or This change is acceptable because it provides appropriate actions for a loss suspending [*el' loops are inoperable, more required RHR loops or SG. If both required RIR because all operations involving a reduction of RCS boron concentration is appropriate change is all forced flow used to ensure proper mixing of RCS boron is lost. This the CTS.

designated as more restrictive because it adds an additional action to and at least one M.3 CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE that all reactor must be in operation. This requirement is modified by a note that states up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

coolant pumps and residual heat removal pumps may be de-energized for the use of the I ITS 3.4.7 also allows the RHR pumps to be stopped for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , but limits hour exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

infrequent The purpose of the I hour allowance is to allow the performance of certain because startup tests which require coolant flow to be stopped. This change is acceptable do not occur should it ensures that boron stratification or inadequate decay heat removal is designated as multiple 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months periods be required to complete the tests. This change period when that more restrictive because it limits an allowance to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months restriction does not currently exist.

in operation, shall be M.4 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not power RI/

determined OPERABLE by verifying correct breaker alignment and indicated alignment and availability. ITS SR 3.4.7.3 requires verification that correct breaker not in operation. This changes indicated power are available to the required RIR pump Page 3 Revision 13 North Anna Units I and 2

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected: ITS 3.4.11 CTS markup Description These CTS Surveillances 4.4.3.2.la and 4.4.3.2.1.b.3 were marked as "See ITS 3.3.1."

1 and 2 are revised to Surveillances were not addressed in ITS 3.3.1. The CTS markups for Unit remove these Surveillances and DOC L.3 is revised to address the change.

one complete CTS Surveillance 4.4.3.2.2 does not require operating the block valve through requirements of ACTION A.4 and cycle of full travel when the block valve is closed to meet the complete cycle full of A.5. ITS 3.4.11 does not require operating the block valve through one This change travel (SR 3.4.11.2) when the block valve is closed to meet any Required Action.

the change and was not addressed. The CTS markups for Unit 1 and 2 are revised to indicate ITS.

DOC L.4 is added to address this difference between the CTS and the The ITS and Bases are unaffected.

03-02-99 REACTOR COOLANT SYSTEM SAFETY AND RELIEF VALVES - OPERATING RELIEF VALVES LIMITING CONDITION FOR OPERATION ACTION: (Continued)

B. 3lock Valves: `ýe D A40i'

1. With one block valve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block valve to OPERABLE status or place its associated PORV in manual control; restore the block valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . (A1#

G'-

2. With both block valves inoperable, ivi-our either restofrthe blo~kCialves to OPERABLE statu or place the PZVs in manual contfiPrestore at last one block 3y 3.f~.-1q'he pr~ovyjsns of Spe, Xc tion 3.O.4

-. e-irt appliale.-*

c9jrQ SURVEILLANCE REQUIREMENTS 4.4.3.2.1 1 ition tL equire i'etgfSpecifon4..each PORV shall be demonstrated OPERABLE:

a.ast once per 31 days by p rming a CHANNEL FUýN NAL excluding valve operatipaand

b. At least once per 18 months by:

. Operatin the PORV through one complete cycle of full travelojK

2. peratlng the solenoid control valves and check valves on the associated A~CA accumulators in the PORV control systems through one complete cycle of. I I full travel, and instrumentation. "-__ IBATON 6ýfthý "_.__flo 01011

c. At least once per 7 days by verifying that the pressure in the PORV nitrogen 4.4.3.2.2 accumulators is greater than the surveillance limit.

Each block valve shall be demonstrated OPERABLE at least once per 92 days by I

operating the valve through one complete c cle of full travel unless the block valve is closed in order to meet Au h nts of ACTIO 3/5n SAecifica mn N. IV4 1.2 NORTH ANNA - UNIT 1 3/4 4-7b CýAmendment No. +189,218 P1a 4-

el 1) 03-02-99 REACTOR COOLANT SYSTEM SAFETY AND RELIEF VALVES - OPERATING RELIEF VALVES LIMITING CONDITION FOR OPERATION ACTION: (Continued)

(Z-':

ý2 B. Block Valves: (Dr1eio d d---,J,,-e

1. With one block valve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block valve to D, : OPERABLE status or place its associated PORV in manual control; restore the block valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months orbe in at least HOT STANDBY

\biithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2. With both block valves inoperable, ;Cithin i ei tr tre e the bl551ves to A ,-, OP statu*s pace the PORVs manual con l; estore a east one ock Avalve to OPERABLE status withinj ebstore maining ino rable lock eTto OPE o or0 at least HOT BY "nthe next 6 lurs and in HO SHUTDOWN. ithin the followig 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

3. e rovisi oSecfali .4are not a ~~ea1.

SURVEILLANCE REQUIREMENTS 4.4.3.2.1 ( ton to ýe uiiremený Pecificaien-45 ach PORV shall be demonstrated OPERABLE:

//xcluding rvalve l perati o ns y d a _C_. "r~n

.? .. ,3 b. At least once per 18 months by:

1. Operating the PORV through one complete cycle of full travel/ýý OI'.-. .:.:,

q, 2. Operating the solenoid gcontrol valves and check valves on the associated I/:r accumulators in the PORV control systems through one complete cycle of full travel, and

.TIO.Noft aC . .eactuatl.n.ins.iiiiih46i..

NEL CALU

c. At least once per 7 days be verifying that the pressure in the PORV nitrogen L

Sqi,aI accumulators is greater than the surveillance limit.

4.4.3.2.2 Each block valve shall be emonstrated OPERABLE at least once per 92 days by

' operating the valve through one complete cle of full travel unless the block valve is closed in order to meet the requirements of ACTION ori.5in Specification 3.4.3.2.

NORTH ANNA - UNIT 2 3/4 4-7b Amendment No. 4--70, 199

DISCUSSION OF CHANGES ITS 3.4.11, PRESSURIZER PORVs 3.4.3.2, Action A.3, states, L.3 (Category 1 - Relaxation of LCO Requirements) CTS in the PORV automatic "With one or both PORV(s) inoperable due to a malfunction control system(s) to control system, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the affected automatic PORV(s) in manual control.

OPERABLE status or place and maintain the affected Test every 31 days and CTS 4.4.3.2.l.a required performance of a Channel Functional L13 the actuation instrumentation CTS 4.4.3.2.1 .b.3 requires a Channel Calibration of automatic control system for every 18 months. ITS 3.4.11 does not require the PORV the LCO requirement and SRs OPERABILITY. This changes the CTS by eliminating for the PORV automatic control system.

are available to perform their The purpose of CTS 3.4.3.2 is to ensure the PORVs because the LCO accident mitigation function. This change is acceptable and components are requirements continue to ensure that the structures, systems, basis. In the applicable maintained consistent with the safety analyses and licensing for manual operator action in MODES for ITS 3.4.11, the PORVs are only credited automatic control system is the event of a steam generator tube rupture. The PORV not required for PORV not needed to perform this function and, therefore, is because less stringent OPERABILITY. This change is designated as less restrictive than were applied in the LCO requirements and SRs are being applied in the ITS CTS.

CTS 4.4.3.2.2 states that each L.4 (Category 7- Relaxation of Surveillance Frequency) closed in order to meet the block valve shall be cycled unless the block valve is A.4 and A.5 require the block valve requirements of ACTION A.4 or A.5. ACTIONS seat leakage. ITS SR 3.4.11.2 to be closed for reasons other than excessive PORV by a Note stating that states that each block valve shall be cycled, but it is modified valve closed in accordance with the SR is not required to be performed with the block requiring a cycle of the block the Required Actions. This changes the CTS by not PORV seat leakage.

valve when the block valve is closed due to excessive can be cycled if needed.

The purpose of CTS 4.4.3.2.2 is to verify the block valve Frequency has been evaluated This change is acceptable because the new Surveillance reliability. With the block to ensure that it provides an acceptable level of equipment seat leakage, opening the valve closed in order to isolate a PORV with excessive leak as the PORV is already block valve increases the risk of an unisolable RCS because Surveillances will be inoperable. This change is designated as less restrictive the CTS.

performed less frequently under the ITS than under Page 5 Revision 13 North Anna Units 1 and 2

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected: ITS 3.4.12 Bases Description operation, The North Anna PORVs are powered by the Instrument Air system during normal the LTOP range, with nitrogen accumulators acting as a backup. However, during operation in feature was not the PORVs are only powered by the backup nitrogen accumulators. This design the ISTS and reflected in the submittal. The ITS 3.4.12 LCO Bases, the Bases for SR 3.4.12.6, ISTS Bases markup, and JFD 8 are revised to reflect this design

LTOPB System 3.4.12 BASES LCO Note 2 states that accumulator isolation is only required (continued) when the accumulator pressure is more than the PORV lift setting. This Note permits the accumulator discharge isolation valves to be open if the accumulator cannot challenge the LTOP limits.

The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

a. Two OPERABLE PORVs; or A PORV is OPERABLE for LTOP when its block valve is open, its lift setpoint is set to the limits provided in the LCO and testing proves its ability to open at this setpoint, and backup nitrogen motive power is available to the R13 PORVs and their control circuits.

b. A depressurized RCS and an RCS vent.

An RCS vent is OPERABLE when open with an area of 2 2.07 square inches.

Each of these methods of overpressure prevention is capable of mitigating the limiting LTOP transient.

APPLICABILITY This LCO is applicable in MODE 4 when any RCS cold leg temperature is

2350 F (Unit 1), 270°F (Unit 2), in MODE 5, and in MODE 6 when the reactor vessel head is on. The pressurizer safety valves provide overpressure protection 0

that meets the Reference 1 P/T limits above 235 F (Unit 1),

270°F (Unit 2). When the reactor vessel head is off, overpressurization cannot occur.

LCO 3.4.3 provides the operational P/T limits for all MODES.

LCO 3.4.10, "Pressurizer Safety Valves," requires the OPERABILITY of the pressurizer safety valves that provide 4 overpressure protection during MODES 1, 2, and 3, and MODE above 2351F (Unit 1), 2701F (Unit 2).

Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.

B 3.4.12-7 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

LTOP System B 3.4.12 BASES SURVEILLANCE SR 3.4.12.5 REQUIREMENTS to (continued) The PORV block valve must be verified open every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for each required PORV to perform its provide the flow path function when actuated. The valve may be remotely verified open in the main control room. In addition, the PORV to keyswitch must be verified to be in the proper position provide the appropriated trip setpoints to the PORV the PORV actuation logic. This Surveillance is performed if is used to satisfy the LCO.

operated The block valve is a remotely controlled, motor valve. The power to the valve operator is not required in removed, and the manual operator is not required locked closed in the inactive position. Thus, the block valve can be does not the event the PORV develops excessive leakage or close (sticks open) after relieving an overpressure situation.

of The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Frequency is considered adequate in view in the operator other administrative controls available to indication and the control room, such as valve position open alarms, that verify that the PORV block valve remains and the keyswitch in the proper position.

SR 3.4.12.6 in the SR 3.4.12.6 requires verification that the pressure PORV backup nitrogen system is sufficient to provide motive R13 an overpressure event. The force for the PORVs to cope with Frequency of 7 days is based on operating experience.

SR 3.4.12.7 after Performance of a COT is required within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months decreasing RCS temperature to

2357F (Unit 1), 270'F verify (Unit 2) and every 31 days on each required PORV to adjust its lift setpoint. A successful and, as necessary, may be test of the required contact(s) of a channel relay of a performed by the verification of the change of state is an single contact of the relay. This clarifies what This is acceptable CHANNEL OPERATIONAL TEST of a relay.

of the acceptable because all of the other required contacts and relay are verified by other Technical specifications per non-Technical Specifications tests at least once with applicable extensions. The COT will refueling interval (continued)

B 3.4.12-11 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

LTOP System B 3.4.12 BASES APPLICABLE RCS Vent Performance (continued)

SAFETY ANALYSES T LSystem satisfies Criterion 2 of Pthe.NC-7)

This LCO requires that the LTOP System is coolant OPERABLE. The LCO when the minimum input and LTOP System is OPERABLE of pressure relief capabilities are OPERABLE. Violation this LCO could lead to the loss of low temperature of the af and violation transient. ;- -s P J

!L4gP yressure mitigation of an operational *TS-P0 *6 s result requires 4? ."*'~,,-. ,

_"o OT_ iotniL-lbe cool nt input capability, Ehe LCO able of

, nle4 ump and one charging pump injectin into the RCS 'and all accumulator discharg a ion va veý-c ose i A.e hen accumulator pressure r ater re mu for the

._ ... ss PTLR./- st, tin RCS dleg tem ue al lowed sZ:2g

n*¢ *

2 ITLRe. TS -F-.2 85-ý The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

jq6a. (Tw__ýrlif Two OPERABLE PORVs: or APORV is OPERABLE for LTOP when its block valve* Lt'l' b Upen, ilts lift tpoint is set to the limito:

power is available to the )and their control circuits. l V ,ee

[2. -Týwo OPE*RABLE R Tsuct--ion relief Ives: or]

An RHR suc on relief valve's OPERABLE for LT~

lwhen its '*R-suction iso xlion valve and it s/HR I["

] .

lsuctiovalve are open ..ts setpoint is a .*or betw n [436.5] psig d [463.5] psig, a d te ing has proven i s ability to open, t this (continued)

B 3.4-65 Rev 1. 04/07/95 WOG STS

ITS 3.4.12, LTOP SYSTEM INSERT 1 SR 3.4.12.6 backup nitrogen system is SR 3.4.12.6 requires verification that the pressure in the PORV an overpressure event. The sufficient to provide motive force for the PORVs to cope with Frequency of 7 days is based on operating experience.

INSERT 2 relay may be performed by the A successful test of the required contact(s) of a channel of the relay. This clarifies what is an verification of the change of state of a single contact This is acceptable because all of acceptable CHANNEL OPERATIONAL TEST of a relay. Technical specifications and the other required contacts of the relay are verified by other interval with applicable non-Technical Specifications tests at least once per refueling extensions.

Insert to Page B 3.4-71 Revision 13 North Anna Units 1 and 2

JUSTIFICATION FOR DEVIATIONS ITS 3.4.12, LTOP SYSTEM pressure is greater The ISTS requires the accumulators to be isolated when accumulator as allowed by the than the maximum RCS pressure for the existing cold leg temperature to be isolated when P/T limit curves. The ISTS is revised to require the accumulators pressure given in the LCO.

accumulator pressure is greater than the PORV lift setpoint of an accumulator injecting The North Anna LTOP analysis does not address the situation but below the maximum RCS with the accumulator pressure above the PORV lift setting the P/T limit curves. The pressure for the existing cold leg temperature as allowed by from accumulator analysis does not address a PORV being used to relieve pressure setpoint (which is also injection. If the accumulator pressure is below the PORV lift injection of an below the limiting pressure for the existing cold leg temperature),

for the existing conditions. This accumulator cannot exceed the maximum RCS pressure C, and a Note to SR revised allowance is stated in an LCO Note, a Note to Condition 3.4.12.3.

be RIK TSTF-285 modified the ISTS Applicability Note to state that the accumulator may for the RCS pressure unisolated when accumulator pressure is less than the maximum provided in the PTLR, existing cold leg temperature as allowed by the P/T limit curves of the Note to an and moved the Applicability Note to an LCO Note. The movement the wording changes LCO Note has been adopted in the North Anna ITS. However, North Anna LTOP analysis, as made to the Note in TSTF-285 are not consistent with the has been revised to be described in the previous paragraph. Therefore, the Note consistent with the North Anna LTOP analysis.

and accumulator isolation will These more stringent controls on accumulator pressure are met.

ensure that the assumptions of the North Anna LTOP design revisions to LCO 3.4.12 made

7. Portions of TSTF-280, Revision 1, are not adopted. The available options are not by TSTF-280, Revision 1, to clarify the application of the North Anna analysis and needed due to the changes made to the LCO to reflect the design.

Instrument Air System and backup

8. The North Anna PORVs are supplied from both the 3 nitrogen nitrogen accumulators during power operation and from the backup the backup nitrogen accumulators are accumulators in the LTOP conditions. Therefore, to verify the OPERABILITY needed for PORV OPERABILITY. A Surveillance is added as needed.

of the backup nitrogen supply. Subsequent items are renumbered Page 2 Revision 13 North Anna Units 1 and 2

Specifications Affected: ITS 3.4.8 Description to reflect that there The title for the ITS 3.4.8 LCO Notes is revised from "NOTE" to "NOTES" are two LCO Notes. The ISTS markup is correct.

RCS Loops-MODE 5, Loops Not Filled 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops-MODE 5, Loops Not Filled LCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

IR13

--- NOTES -----------------

5-1

1. All RHR pumps may be removed from operation for 3.

R4

15 minutes when switching from one loop to another provided:

a. The core outlet temperature is maintained > 10OF below saturation temperature; R13

b. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1; and

c. No draining operations to further reduce the RCS water volume are permitted.

2. One RHR loop may be inoperable for

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

APPLICABILITY: MODE 5 with RCS loops not filled.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RHR loop A.1 Initiate action to Immediately inoperable, restore RHR loop to OPERABLE status.

North Anna Units 1 and 2 3.4.8-1 Rev 13 (Draft 1), 01/08/02

Specifications Affected: ITS 3.4.18 Bases Description the water in the RCS is used The LCO Bases for ITS 3.4.18 contained the statements, "Because loop water boron to fill the loop, it is not necessary to establish limits on the isolated are not opened within two concentration or temperature. However, if both isolation valves portion of the loop may occur and it hours, changes in water boron concentration in the isolated leg and cold leg isolation valves is necessary to verify the boron concentration or close the hot statements are not in the ISTS.

and follow the requirements of the LCO to reopen them." These and Surveillance Requirements These statements are not consistent with the Required Actions and have been deleted.

LCO Bases for ITS 3.4.18. The A typographical error is corrected in the first paragraph of the Bases markup does not require word "values" is changed to the correct word "valves." The ISTS correction.

RCS Isolated Loop Startup B 3.4.18 BASES LCO Loop isolation valves are used for performing maintenance when the unit is in MODE 5 or 6. This LCO governs the return to operation of an isolated loop (i.e., the hot and cold leg loop isolation valves are initially closed) and ensures that the loop isolation valves remain closed unless acceptable IR13 conditions for opening the valves are established.

There are two methods for returning an isolated loop to operation. The first method is used when the isolated loop is filled with water. When using the filled loop method, the hot leg isolation valve (e.g., the inlet valve to the isolated portion of the loop) is opened first. As described in LCO 3.4.18.a, the water in the isolated loop must be borated to at least the boron concentration needed to provide the required shutdown margin prior to opening the hot leg isolation valve. This ensures that the RCS boron concentration is not reduced below that required to maintain the required shutdown margin. The water in the isolated loop is then mixed with the water in the RCS by establishing flow through the recirculation line (which bypasses the cold leg isolation valve). After the flow through the recirculation line has thoroughly mixed the water in the isolated loop with the water in the RCS and it is verified that the isolated loop temperature is no more than 20'F below the temperature of the RCS (to avoid reactivity additions due to reduced RCS temperature), the cold leg isolation valve may be opened.

The second method for returning an isolated loop to operation is described in LCO 3.4.18.b and is used when the isolated loop is drained of water. In the drained loop isolated method, the water in the RCS is used to fill the the 1R13 portion of the loop. The LCO also requires that pressurizer water level be established sufficiently high prior to and during the opening of the isolation valves to ensure that the inadvertent opening of all three sets of loop isolation valves on three drained and isolated loops would not result in loss of net positive suction head for the Residual Heat Removal system.

The LCO is modified by a Note which allows Reactor Coolant Pump (RCP) seal injection to be initiated to a RCP in a drained, isolated loop. This is to support vacuum assisted backfill of the loop. In this method, a vacuum is drawn on the isolated loop prior to opening the cold leg isolation valve in order to minimize the amount of trapped air in the loop and to minimize the need to run the RCP in the isolated loop to clear out air pockets. In order to draw a vacuum on (continued)

North Anna Units 1 and 2 B 3.4.18-3 Rev 13 (Draft 1), 01/08/02

ITS 3.4.18 BASES, RCS ISOLATED LOOP STARTUP INSERT 4 There are two methods for returning an isolated loop to operation. The first method is used when the isolated loop is filled with water. When using the filled loop method, the hot leg As isolation valve (e.g., the inlet valve to the isolated portion of the loop) is opened first.

must be borated to at least the described in LCO 3.4.18.A, the water in the isolated loop the boron concentration needed to provide the required shutdown margin prior to opening reduced below hot leg isolation valve. This ensures that the RCS boron concentration is not loop is that required to maintain the required shutdown margin. The water in the isolated line then mixed with the water in the RCS by establishing flow through the recirculation line (which bypasses the cold leg isolation valve). After the flow through the recirculation and it is has thoroughly mixed the water in the isolated loop with the water in the RCS of verified that the isolated loop temperature is no more than 20 'F below the temperature cold leg the RCS (to avoid reactivity additions due to reduced RCS temperature), the isolation valve may be opened.

in LCO 3.4.18.B The second method for returning an isolated loop to operation is described the and is used when the isolated loop is drained of water. In the drained loop method, that water in the RCS is used to fill the isolated portion of the loop. The LCO also requires of high prior to and during the opening the pressurizer water level be established sufficiently of all three sets of loop isolation the isolation valves to ensure that the inadvertent opening suction valves on three drained and isolated loops would not result in loss of net positive head for the Residual Heat Removal system.

injection to The LCO is modified by a Note which allows Reactor Coolant Pump (RCP) seal backfill be initiated to a RCP in a drained, isolated loop. This is to support vacuum assisted the cold of the loop. In this method, a vacuum is drawn on the isolated loop prior to opening and to minimize leg isolation valve in order to minimize the amount of trapped air in the loop In order to draw a the need to run the RCP in the isolated loop to clear out air pockets.

The boron vacuum on the isolated loop, the RCP seals must be filled with water.

concentration of the water used for seal injection must meet the same requirements as the in order reactor coolant system and the loop must be drained prior to starting seal injection isolated required remains in the to be sure that no water at a boron concentration less than loop.

to be closed for The LCO is modified by a Note which allows a hot or cold leg isolation valve requirements up to two hours without considering the loop isolated and meeting the LCO for necessary maintenance and testing on the when opening the closed valve. This allows not reopened with two hours, it is valves and the valve operators. If the closed valve is of follow the requirements necessary to close both isolation valves on the affected loop and there is a possibility the LCO when reopening the isolation valves. This is required because that the water in the isolated loop has become diluted or cooled to the point that reactivity reintroduction of the water into to the reactor vessel could result in a significant change.

Revision 13 Insert to Page B 3.4-104 Revision 13 North Anna Units 1 and 2

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected: ITS 3.5.2 Bases Description to hot leg The Bases Background of ITS 3.5.2 state that the shift from cold leg recirculation have been revised recirculation occurs approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months after an accident. The analyses hours. The ITS Bases and the swap to hot leg recirculation now occurs within approximately 5 and ISTS Bases markup are revised to reflect this value.

ECCS-Operati ng B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.2 ECCS-Operating BASES BACKGROUND The function of the ECCS is to provide core cooling and negative reactivity to ensure that the reactor core is protected after any of the following accidents:

a. Loss of coolant accident (LOCA), coolant leakage greater than the capability of the normal charging system;

b. Rupture of a control rod drive mechanism-control rod assembly ejection accident;

c. Loss of secondary coolant accident, including uncontrolled steam release or loss of feedwater; and

d. Steam generator tube rupture (SGTR).

The addition of negative reactivity is designed primarily for the MSLB where primary cooldown could add enough positive reactivity to achieve criticality and return to significant power.

There are three phases of ECCS operation: injection, cold leg recirculation, and hot leg recirculation. In the injection phase, water is taken from the refueling water storage tank (RWST) and injected into the Reactor Coolant System (RCS) through the cold legs. When sufficient water is removed from the RWST to ensure that enough boron has been added to maintain the reactor subcritical and the containment sumps have enough water to supply the required net positive suction head to the ECCS pumps, suction is switched to the containment sump for cold leg recirculation.

Within approximately 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months , the ECCS flow is shifted to R13 the hot leg recirculation phase to provide a backflush, which would reduce the boiling in the top of the core and any resulting boron precipitation.

The ECCS consists of two separate subsystems: High Head Safety Injection (HHSI) and Low Head Safety Injection (LHSI). Each subsystem consists of two redundant, 100%

capacity trains. The ECCS accumulators and the RWST are also part of the ECCS, but are not considered part of an ECCS flow path as described by this LCO.

(continued)

B 3.5.2-1 Rev 13 (Draft 2), 01/25/02 North Anna Units 1 and 2

ECCS-Operating B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

B 3.5.2 ECCS-Operating BASES BACKGROUND The function of the ECCS is to provide core cooling and negative reactivity to ensure that the reactor core is protected after any of the following accidents:

a. Loss of coolant accident (LOCA), coolant leakage greater system: than the capability of the normal charging I-jý

b. VJtoodttejec~tiown a~ccident;

c. Loss of secondary coolant acciaent. including uncontrolled steam release or loss of feedwater: and

d. Steam generator tube rupture (SGTR).

The addition of ne at activity is. designed primarily for the (os6 of secondar*f coolant apei dentw cooldown could add enough positive reac ivity to achieve ),,

criticality and return to significant power. _

There are three phases of ECCS operation: injection, cold leg recirculation. and hot leg recirculation. In the injection phase, water is taken from the refueling water storage tank (RWST) and injected into the Reactor Coolant System (RCS) through the cold legs. When sufficient water is removed from the RWST to ensure that enough boron has been added to maintain the reactor subcritical and the containment sumps have enough water to supply the required net positive suction head to the ECCS pumps, suction is switched to-th-e-containment sump for cold leg recirculation.

\ approximahours, the ECCS flow is shifted to the hot leg recirculation phase to provide a backflush.

which would reduce the boiling in the top of the core and any resulting boron preciP~ttion.

The ECCS consists of e se arate subsystems: r and!?a and r 1,V a Each

( T~c,'1d* su system consists of two redundant, 100X capacity rains.

The ECCS accumulators and the RWST are also part of the (continued)

WOG STS B 3.5-10 Rev 1. 04/07/95

Specifications Affected: ITS 3.5.6 Bases Description to The ITS and ISTS LCO Bases for ITS 3.5.6 state, "It should be noted, however, that changes pursuant to applicable MODES cannot be made until the BIT is restored to OPERABLE status the provisions of LCO 3.0.4." The changes made to LCO 3.0.4 by TSTF-359, which is "It incorporated in the North Anna ITS, make this statement inaccurate. It is revised to state, until the BIT is should be noted, however, that changes to applicable MODES cannot be made ITS Bases restored to OPERABLE status, except as provided by LCO 3.0.4." This affects the and ISTS markup. Bases JFD 9 is added to discuss the change.

BIT B 3.5.6 BASES ACTIONS B.1, B.2, and B.3 (continued)

When Required Action A.1 cannot be completed within the required Completion Time, a controlled shutdown should be initiated. Six hours is a reasonable time, based on operating experience, to reach MODE 3 from full power conditions and to be borated to the required SDM without challenging unit systems or operators. Borating to the required SDM assures that the unit is in a safe condition, without need for any additional boration.

After determining that the BIT is inoperable and the Required Actions of B.1 and B.2 have been completed, the tank must be returned to OPERABLE status within 7 days.

These actions ensure that the unit will not be operated with an inoperable BIT for a lengthy period of time. It should be noted, however, that changes to applicable MODES cannot be made until the BIT is restored to OPERABLE status, except as provided by LCO 3.0.4. R13 C.1 Even though the RCS has been borated to a safe and stable condition as a result of Required Action B.2, either the BIT must be restored to OPERABLE status (Required Action C.1) or the unit must be placed in a condition in which the BIT is not required (MODE 4). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time to reach MODE 4 is reasonable, based on operating experience and normal cooldown rates, and does not challenge unit safety systems or operators.

SURVEILLANCE SR 3.5.6.1 REQUIREMENTS Verification every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the BIT water temperature is at or above the specified minimum temperature is frequent enough to identify a temperature change that would approach the acceptable limit. The solution temperature is also monitored by an alarm that provides further assurance of protection against low temperature. This Frequency has been shown to be acceptable through operating experience.

North Anna Units 1 and 2 B 3.5.6-4 Rev 13 (Draft 1), 01/09/02

BIT B 3.5.6 BASES ACTIONS A.1 (continued) minimum, prompt action must be taken to raise the temperature and declare the tank OPERABLE, or thegn must be placed in a MODE in which the BIT is not require.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time to restore the BIT to OPERABLE Times estab]_she.

status is consistent with other Completion that for loss of a safety function and ensures the "

will not operate for long periods outside of the safety analyses.

B.1, B.2, and B.3 When Required Action A.1 cannot be completed within the required Completion Time, a controlled shutdown should be initiated. Six hours is a reasonable time. based on operating experience, ta reach MODE 3 from full power conditions and to borated to the r d thout challenging ems or operators. Borating to thee /)

required SD assures that the is in a safe condition.

without need for any additionaa boration.

After determining that the BIT is inoperable and the Required Actions of B.1 and B.2 have been completed. the tank must be returned to OPERABLE status within 7 days.

These actions ensure that the ?will not be operated with an inoperable BIT for a en hy p-eriod o i should be noted, however. that changes to applicable MODES status as cannot be made until the BIT is restored to OPERABLE Ice,~1 / ur t ,iýnsofLCO 3.0.4. leaI~'

C.1 Even though the RCS has been borated to a safe and stable condition as a result of Required Action B.2. either the BIT must be estored to OPERABLE status (Required Action C.1) or e must be placed in a condition in which the BIT is ot required (MODE 4). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time to reach MODE 4 is reasonable, based on operating experience and normal cooldown rates, and does not challenge safety operators. dr (continued)

B 3.5-39 Rev 1, 04/07/95 WOG STS

JUSTIFICATION FOR DEVIATIONS ITS 3.5.6 BASES - BORON INJECTION TANK Injection System" and it has been

1. North Anna does not use 'the system name, "Boron removed from the Bases.

changes) to the ISTS which reflect the

2. Changes are made (additions, deletions, and/or system description, analysis, or licensing plant specific nomenclature, number, reference, basis description.

to be consistent with the ISTS Writers

3. Editorial change made for enhanced clarity or Guide.

plant specific information/value has been

4. The brackets have been removed and the proper provided.

volume are the same. Changes are made to

5. The Boron Injection Tank volume and usable the Bases to reflect the design.

on Technical Specifications

6. The criteria of the NRC Final Policy Statement Therefore, references in the Improvements have been included in 10 CFR 50.36(c)(2)(ii).

revised in the ITS Bases to reference ISTS Bases to the NRC Final Policy Statement are 10 CFR 50.36.

made regarding Boron Injection Tank

7. Changes are made to describe specific assumptions boron concentration for specific analyses.

to verify BIT parameters (temperature,

8. The LCO paragraph, "If the equipment used to be inoperable, then the BIT is also volume, and boron concentration) is determined this equipment to verify these parameters inoperable," is not adopted. Surveillances use are required to verify that the BIT is are within limits at appropriate frequencies. They the BIT inoperable. The BIT is OPERABLE, but their inoperability does not render as long as the Surveillance considered capable of performing it's safety function within the required Frequencies. This Requirements for these parameters have been met surveillances in other sections of is consistent with the use of equipment used to perform NUREG-1431.

ends with the statement, "It should be noted,

9. The Bases to ACTIONS B.1, B.2, and B.3 be made until the BIT is restored to however, that changes to applicable MODES cannot of LCO 3.0.4." Revisions made to LCO OPERABLE status pursuant to the provisions is revised to state," It should be 3.0.4 have made this statement incorrect. The statement cannot be made until the BIT is noted, however, that changes to applicable MODES by LCO 3.0.4." This statement is restored to OPERABLE status, except as provided consistent with LCO 3.0.4 requirements.

Page 1 Revision 13 North Anna Units 1 and 2

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected: ITS 3.6.7 Bases Description Recirculation The LCO Bases of ITS 3.6.7 do not describe what constitutes an OPERABLE RS System is added to the Spray (RS) system. A description of what constitutes an OPERABLE for the Improved ITS 3.6.7 LCO Bases for consistency with NEI 01-03, "Writer's Guide of the impact of the Quench Standard Technical Specifications," section 4.2.4. A discussion is also added to the LCO Spray System and casing cooling inoperability on RS OPERABILITY Background section of the Bases. The information added to the LCO Bases is taken from the JFD 12.

Bases. This affects the ITS Bases, the ISTS Bases markup, and added

RS BSystem 3.6.7 BASES the APPLICABLE the containment atmosphere temperature exceeds that there SAFETY ANALYSES containment design temperature is short enough containment.

(continued) would be no adverse effect on equipment inside Therefore, it is concluded that the calculated transient for the containment atmosphere temperatures are acceptable SLB and LOCA.

analysis The RS System actuation model from the containment the is based upon a response time associated with exceeding achieving High-High containment pressure signal setpoint to delay in full flow through the RS System spray nozzles. A of response time initiation provides conservative analyses The RS peak calculated containment temperature and pressure. the delay System's total response time is determined by timers and system startup time.

the For certain aspects of accident analyses, maximizing In calculated containment pressure is not conservative.

Core particular, the cooling effectiveness of the Emergency a LOCA Cooling System during the core reflood phase of analysis increases with increasing containment backpressure. is For these calculations, the containment backpressure minimize, calculated in a manner designed to conservatively rather than maximize, the calculated transient containment K (Ref. 3).

pressures in accordance with 10 CFR 50, Appendix The RS System satisfies Criterion 3 of 10 CFR 50.36(c) (2)(ii).

During a DBA, one train (one inside and one RS outside RS LCO or two outside subsystems of subsystem in the same train) heat the RS System are required to provide the minimum in the safety analysis. To ensure removal capability assumed and the that this requirement is met, four RS subsystems ensure that casing cooling tank must be OPERABLE. This will case at least one train will operate assuming the worst and the loss single failure occurs, which is no offsite power of the I R13 of one emergency diesel generator. Inoperabilitythe casing casing cooling tank, the casing cooling pumps, or of cooling valves, piping, instrumentation, or controls, on RS the QS System requires an assessment of the effect subsystem OPERABILITY.

Each RS train consists of one RS subsystem outside Each RS containment and one RS subsystem inside containment. one subsystem includes one spray pump, one spray cooler, (continued)

B 3.6.7-4 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

RS BSystem 3.6.7 BASES LCO 1800 coverage spray header, nozzles, valves, piping, (continued) instrumentation, and controls to ensure an OPERABLE flow path capable of taking suction from the containment sump. I R13 APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause an increase in containment pressure and temperature requiring the operation of the RS System.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Thus, the RS System is not required to be OPERABLE in MODE 5 or 6.

ACTIONS A.1 With one of the RS subsystems inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days.

The components in this degraded condition are capable of providing at least 100% of the heat removal needs (i.e.,

approximately 150% when one RS subsystem is inoperable) after an accident. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the RS and QS systems and the low probability of a DBA occurring during this period.

B.1 and C.1 With two of the required RS subsystems inoperable either in the same train, or both inside RS subsystems, at least one of the inoperable RS subsystems must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded condition are capable of providing 100% of the heat removal needs and 3600 containment spray coverage after an accident.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal capability afforded by the OPERABLE subsystems, a reasonable amount of time for repairs, and the low probability of a DBA occurring during this period.

D.1 With the casing cooling tank inoperable, the NPSH available to both outside RS subsystem pumps may not be sufficient. The inoperable casing cooling tank must be restored to OPERABLE RAI I 3.6.7-4 status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded IR1 (continued)

B 3.6.7-5 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2

RS System C06)

BASES APPLICABLE The RS System actuation model from the containment analysis SAFETY ANALYSES is based upon a response time associated with exceeding the (continued) High-High containment pressure signal setpoint to achieving full flow through the RS System spray nozzles. A delay in response time initiation calculated containmentprovides conservative temperature analyses The and pressure. of S~peak mna RS siJ ýjeseres onse elay total Snl*.stem's ti 1 ,st+

ýenera~tyr Bin tieconni s_

nedn ise system t* *.*

L startup time.

For certain aspects of accident analyses, maximizing the calculated containment pressure is not conservative. In particular, the cooling effectiveness of the Emergency Core Cooling System during the core reflood phase of a LOCA analysis increases with increasing containment backpressure.

For these calculations, the containment backpressure is calculated in a manner designed to conservatively minimize, rather than maximize, the calculated transient containment pressures in accordance with 10 CFR 50. Appendix K (Ref. 3).

The RS System satisfien oftrNjol c*Y A0 ý,A2*- leR5... -q.rl LCO During a DBA, one train of e esstem) tem(* 6*

required to provide the minimum heat removal capability /fT - C) assumed in the safety analysis. To ensure that this requirement is met, four RS subsystemsAnd tank]must be OPERABLE. -This will ensure that at least one train will operate asuminc asing cooling up*case single failure the worst (j-- K3 occurs. which is( *v APPLICABILITY In MODES 1. 2. 3. and 4. a DBA could cause an increase in containment pressure and temperature requiring the operation of the RS System.

In MODES 5 and 6. the probability and consequences of these events are reduced due to the pressure and temperature required to of limitations be these MODES. Thus. the RS System isno not OPERABLE in MODE 5 or 6. o; *r % _\,-ý WOG STS B 3.6-103 S~(continued)

Rev 1. 4/0/9 I?'I3

ITS 3.6.7 BASES, RECIRCULATION SPRAY SYSTEM INSER pumps, the casing cooling Inoperability of the casing cooling tank, the casing coolingsystem requires an assessment of valves, piping, instrumentation, or controls, or of the OS the effect on RS subsystem OPERABILITY.

containment and one RS subsystem Each RS train consists of one RS subsystem outside one spray pump, one spray cooler, one inside containment. Each RS subsystem includes instrumentation, and controls to 1800 coverage spray header, nozzles, valves, piping, suction from the containment sump.

ensure an OPERABLE flow path capable of taking Insert to Page B 3.6-103 Revision 13 North Anna Units 1 and 2

JUSTIFICATION FOR DEVIATIONS ITS 3.6.7 BASES, RECIRCULATION SPRAY SYSTEM are modified to reflect this generator. References to the worst case single active failure plant specific assumption.

the word "approximately" is

10. In ISTS 3.6.6E Background and Action A.1 Bases sections, to the RS heat removal added to "50%" and "150%," respectively. This is in reference The exact capacity capability of one RS subsystem and 3 RS subsystems, respectively.

Adding this change makes the for each RS subsystem varies, but is approximately 50%.

statements more accurate.

D.1 to clarify available RS

11. Information is added to the Bases for ITS Required Action cooling capability when the casing cooling tank is inoperable.

what is required for an

12. Information is added to the LCO Bases to clearly define Writer's Guide.

OPERABLE RS subsystem in accordance with the ITS reference the "ASME Code for

13. The Bases are revised to refer to the ASME Code and discussing the Inservice Operation and Maintenance of Nuclear Power Plants" when ASME Code and "ASME, Testing Program, instead of referencing Section XI of the has adopted the ASME Code Boiler and Pressure Vessel Code,Section XI." North Anna the 1995 Edition and the 1996 for Operation and Maintenance of Nuclear Power Plants, adoption, references to Section Addenda, as required by 10 CFR 50.55a(b)(3). With this incorrect when discussing the XI and to the ASME Boiler and Pressure Vessel Code are Bases.

Inservice Testing Program in the North Anna ITS and Page 2 Revision 13 North Anna Units I and 2

v t e Letter Sequence Request
TAC:MB0799, Nis Power Range Channel Daily SR TS Change to Address LOW Power Decalibration, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed) TAC:MB0800, Nis Power Range Channel Daily SR TS Change to Address LOW Power Decalibration, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed)
Initiation Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Administration Questions Answers Results Approval Other: ML020650715, ML020840253, ML021220061, ML021220088, ML021550518
MONTHYEAR2002-02-20 [Table View]

ML020510089

Text

Subject:

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