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.

5-5-83 the defined terms of this section appear in capi ze t p and are

~4 ~~

applicable throughout these Technical Spcfcto 1.1 ACTIObsha el be that part. of a Specification which prescribes G

a

ýu-eunder desi nated conditions.

AXIAL FLUlX DITT~lC

o.

dpbiLOI ei 2

S1.2 AXLQ FLUX sall be the difference in normalized flux signals, A F 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'

C-h Cai," 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, On

~uto and s IE. include FtTNCVT!

TIST e

CHANNIEL tX.L-1YRATION may be performed b an series of sequential.- overlappin8 or total channel steps is

.t t

tira i

ý tte.

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 (7cA L

27) 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"~

1,6.1 All penetrations required to be closed during acciden 3t4 condi tio ns, are eith er:

\\

NORTH ANNA - UIT 1 1-1 Amendment No.

10, 4

. CLI ac;ITh rrk If 11 keL. H

(/:.:ýo ýU&ýFAMOýAePýl 1.0&DEFINITIORS Il,A-%.6.3-r C"ý e )

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

DEFiNmONS_(Conhiriuedl

(:

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

System. or 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~ith nV*

Wfof SpeaMtir, 3.6.1.2j~

<a.J~~b3 ~

1.6.5 (The "seaigflCVfl~

assodale-d560 th each

-emln (eG ea.o4 or Ofns (isRALE

_____TS

£OprcC r-v AK AM 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 po Wv~e c~creWne tw fo the Oj~,w I)I bad cycle. These cceeeM ci spe~f4 knws smi Oletemtnd o feach in gcira wit' spacl

,vdr~eer optrbnWti teelmt sadrse in ft*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 Powe ari

&M79 Reacar sier.,z~~j 3

1-.kVEFaF !nisiTnF(-ATIN r-m1RGY 1.11 Eshall be the a&"fag@ (w*Wzo~d in pcropwbon 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 selo 1;.,1-0c Pell. It' KAI 1 bi)

FýAt 3 PI-25r e 3 a -F I/

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

15 D6E7INITIONS r5-5-83

]T7

Sec *t,*on heI b

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' A4 pf-D-J

~

~;4 VJAJ.Ph" Tan clees 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 4 j kn" 1

aown values of the paraneter cýh the channel monitors.

The BA

~ 4,.-

ON shall encom a t he sml hbannal.

trl I un ctip u

'1Iclude

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INLn ah CRNE CALIBRATION any be performed bFy

-any series 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*a oi the injection of a si1-1ateed signal into the channel as close to the sensor as practicable to verify OPERAJILIM TT.6E:

b.

sta le c

~annl,9 t a.

ecto oa a a

,ted

+/-gal a

z thea semsor tin a erif OEAEIT cldng-'alarm and/or trip ftcr~os

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ONTAINMMNT UqTGRITT 1.6 CONT-AINKE IN7ECRITV-shall exist when*ee7 LA.~

I 2S6.II I'I, i"f

'ii LA I I conditions~V-M ar ihr:-'

.bit NORTH ANNA UNIT 2 11Amendment No. 3 WillI c~

3-I

/1,12 w4reA to be closed during accident

(PV' I

e DEFINITONS (C-0ftinud)

a.

Cpabe o beng j0Wby an OPRBE contanmmr auomatic isolhion valve iedhI*

Isystem.

or Eb.

Cosied by manual valves. blind fiage. sor deaaoi~ed autoratic valves secured in thO' ciosed postE.s except tot' valves thai are open urxer aammzisirative woroas I emale 1.6.3 Eac a" ERAB iL'E'.. p" 5m`uain to..13 1.6.4 (m~e contaimetTr isaimAge raiss are Ma___of__

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ý.el, _soLo~f y~cA 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* completionfl at rIswIT 01 GIt WffprWf 10 81 ate tDE PERAT1N!

I IMMT RFPO (3Tj P0iY~r1

&X 1.9 The CORE OPERATG LIMITS REP'ORT h Ie

-W e~

Una4snww WCM& V 6jj3

ir~sjý,

tor VW we r 4jjmLj0 m red cycle. Thes ycy6-epWc~a linus shot be deitriiied Wa each rebad Cycle in at~oardw with Spet:

n Plait 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 &nxway preseml The thy, od osecor'ersiontaboorsu!1f'rthit caJimilabo "lla be Uai ksed kiTabitle I 11DT-148".I44

~Lkwbdn @1 D~rsianza Power and lest Rea= SIL.s.j7~~

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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 D coWtaMMhe15730fW1S1p 5fl)O a

suhemoUlofPavesraige betandiparvna

-energies per disirIagratiof (in U.V) 11o moops.

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 In the woolaft.*

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

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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 channel output such that it responds vith the necessary range and accuracy to known values of the parameter which the channel monitors.

The CHANNEL CALIBRA TION shall encompass the entire-channel Including.-the naopr. and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST.

The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total 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 tions and/or status derived from independent Instrumentation ch1anels measuring the same parameter.

CRAMEL FUNCTIONAL TEST 1.5 A CHANNEL FUNCTIONAL TEST shall be:

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

I Lo 3.o J L

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

sensor to verify 0PMEIL*ITT including &Utra and/or trip fu

_C0N'TAIN*T TNTnGRTTT NORTH ANNA -

UNIT 1 1-1 Amendment No. 10, 4 8 "1,0

'4' R A I 1

i*nto the mct'tous.

t 0. ýc 4 J C>

rr-5 3,611 0K1 4-22-94 lRAI3,.-

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1.64 The CT33jVV1Wft baga fate$ ame w~if the kboftOfSP

~ion 3.L¶.2aw 1.6.5 o al m~q-lrechanusm

04. wo Oqin tCrrffn)l i Ff I FAKiCM

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1.7 CONTROLLED LEAKAGE &Wa be Vwa seW wowe fbw

~IeD V ie f*a&=

COOM r-nRF At TERATIOPJ 1.8 CORE ALTERATION OWia be PIe f Ooehri u

w*zjabn Of anW CMVrwr' w~tin the rsaor prosssut vessel With theP vesselI heed renwved WOd WGI in PmS vernl MSPni~mon ml CORE ALTERATION thanl nc prockxe conqietln ml nuvamm of a WicOflf K Io a saeo cowmeaiv N

okf 1.9 The CORE OPERATING UIMrTS REPORT b Peu si~e~ domux"Of Pl provie core op"Mmw 6ii" tor Pie awm" operatin mreb cycle. These" leyd-spue cm op""ain Imbthat la be cetoenmred tar each re cycle in~ m~manc wkh Specgcztbn "S 1.7 Plait ope rulvn wtftn Voss cpernlu kiii be 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 no Vitroild do"e as the qpa7Ky and mb~cwajm 011-131, 132. 1-133. 1-134 anid 1-135 eSualy pm**Mr The ttlfoid do"e awrweron tacuxs used to Pie cakljtatlon shalI be Pi4 ooebd in rable Ul dl TID.14b44. Ca4aiudon of Dkuancs~ Factors I-or Power anid I sto Rew SAW.

=RVFAM:F nIRINTF-MA71eWJ PW=DeZW

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I-11.11 "1ha be Pue evvme to*~a in propr~lon mfta Vewcosvaftn of each ra JkwumL fde Sin the re amm WobJ tP rm W1 VwW w

of ig) of Pt um o.fl ft Pu 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

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I-T-5 b3 5-5-83 L-&O 342 The defined terms 0

t s

section appear in capitalized type and are applicable throughout these Technical Specifications.

ACTION 1.1 ACTION shall be that part of a Specification which prescribes remedia 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 channel output such that it responds with the necessary range and accuracy to 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 CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire-ckannal 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

ith other indica tions and/or status derived from independent instrumentation channels measuring 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 as close to the sensor as practicable to verify OPERABILITY-including alarm and/or trip functions.

ad

b.

Bistable channels

-the injection of a

simualated signal into tha shall*AI*T1 exist when:

Ofe<~i pentratio req uiredt o ng b

d 1-1 NORTH ANNA -

UNIT 2 Amendment No. 3 RNT RAI o/.

i 1tj 5 Ts5 1.0 DEFI :NITIONS I

KD I1

1.0 DEFINMONS (Continued) 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

~iwm socrvt amt pe 04;1L.

welcls, bellow*3r is

=tRAI.E I)OtR~

DIFAKAGF 1.7 CONTROLLED L~

puny seaM.

QDRF A1 TERATION WJAGE shal bet it seal water flow suaie ID the reactor cool 1.6 CORE ALTERATION "Ial be the rrvveme or mer~ulatlon of any =iinent wr t reactor pressure vessel with the vessel head removesd anid fke in the vsseL Muspesimof 0

CORE ALTERATION &NIl rnot pre~.ad wflp~tn ofl0 move wme cg a cwortoeni 'oas consevative positio a&at CQPF flPFRAT1NI LIMITS REPORT 1.9 The CORE OPERATING UMrrS REPORT is the w*.specfic doctmeft VWn pnwk core coerwaVn binus for the crram woorafingrel ev~cvde Thm~

-~~u mwm brrwts "hIl be dleterrmined Wp eachi 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

'E Shall 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

.ene rpies 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.

4-22-94 12M flvalve vaive*

t tin the'

-J1T5 NORTH ANNA.- UNIT 2 1-2 Armv~lnts* No. 3z 3 n. 16 2 I

.Iu-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 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 action expeditiously. Containment structural integrity problems once confirmed are unlikely 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 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time frame is 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 LA. 1 (Type 2 - Removing Descriptions of System Operation) CTS 1.6 states, "CONTAINMENT INTEGRITY shall exist when:... 1.6.2 All equipment hatches are closed and sealed." 3.6.1 states, "Containment shall be OPERABLE." This changes the CTS by moving the reference to the equipment hatch being closed to the Bases.

V-4 1 The change deleting the phrase "and sealed" is addressed by DOC L.1.

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 protection of public health and safety. The ITS still retains the requirement to perform required visual inspections and leakage rate testing in accordance with the Containment Leakage Rate Testing Program in accordance with 10 CFR 50 Appendix J, Part B, which would provide verification that the equipment hatch is closed. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system operation is being removed from the Technical Specifications.

LA.2 (Type 2 - Removing Descriptions of System Operation) CTS 1.6 states, PA "CONTAINMENT INTEGRITY shall exist when:... 1.6.1 All penetrations required 3 C.1--ý to be closed during accident conditions are either: a. Capable of being closed by an 3V -1 OPERABLE containment automatic isolation valve system, or b. Closed by manual e

valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open under administrative control as permitted by Specification 3.6.3.1." CTS 1.6.5 states, "The sealing mechanism associated with North Anna Units 1 and 2 Page 3 Revision 14

DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT each penetration (e.g. welds, bellows, or 0-rings) is OPERABLE." This changes the CTS by moving the 1.6.1 and 1.6.5 portions of the definition to the 3.6.1 Bases.

AuI The removal of these details, which are related to system operation, from the 3-0-3 Technical Specifications is acceptable because this type of information is not

ý,14 necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the containment to be OPERABLE and the relocated material describes aspects of OPERABILITY. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled.

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

LESS RESTRICTIVE CHANGES L. I (Category I - Relaxation of LCO Requirements) CTS 1.6 states, "CONTAINMENT INTEGRITY shall exist when:... 1.6.2 All equipment hatches are closed and sealed."

3.6.3 states, "Each containment isolation valve shall be OPERABLE." This changes the CTS by not including an explicit reference to sealing the equipment hatches. The

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

R The purpose of CTS 1.6.2 is to help provide assurance that the equipment hatches can perform their safety function. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The Containment Leakage Rate Testing Program requires testing be performed in accordance with 10 CFR 50 Appendix J, Part B, requiring the containment isolation valves, including the equipment hatch, is OPERABLE, but there is no specific mention of sealing the equipment hatches. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

North Anna Units 1 and 2 Page 4 Revision 14

IT5 3,6 bZ p

rnimflNS ICoritirmjed

4-22-94

a. Capable of being ciowe by an OPERABLE crxmanmer ammra=i mosm a lo sy*mer. or

b.

Closed by nwuai vafre. blind lanpe, or deacated amomtirru.

vatm-j secured' in their clos poskios eolS for S vabks that ame open 13110S SW~5acog r&

i'roI ammr s

by confMan

.6..1 9 Al 3.6.1-1

!Ap5-0 e-z PbI/

1.6.

(AN 9C rK tutas ýarf

.<S Kte J's 3AuI I.".

Each air bwlCa OPIERABLE pwwMer So SpecMicatimn3313

,*swLowimsawnvwtthor-hwwbg.

9

~~Ps I I? WT 2 -12i.?

i "1.7 CONTROLLED LEAKAGE shin be Vhal sa" wawe flow spie ID fte Mawr Cool=m FLO seaklM 1.6 CORE ALTERATION shin be the n wmover ori m rrs'n cc WWy ewrgonemwa v Pi rua~o pressur vessel with Pus vw* aI huid mnwvvsd and kuel in Pie vwi

. aispersion of CORE ALTERATION "tl not precbk0e wri*ttn at nvvnnwm of a wvconetw io a saet 1.9 The CORE OPERATINLG UWfTS REPORT Is the unk-opecft doomewl VWa povdg com opwraftku bT*s for the c~mm opeluling relod cycle. Thes cyd4.spe~ir cm Oeat limbe shOa be Marnaemmd 1w eaci reoe qcfl In MidaI with Speffmtdw 6..1.7 i "opratin wfttn these opehftVu lib Isor me mduse 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 1.11 E sll be ft averae (we~ indb' p c pcrwdcr So fte conce mtimof

@ e~sc rodiorucl inthe re aaw cookm VtP this 04sm a

ofm*l) of fte sun of3 atverape boa anid qwnv orerpes per diairmqpaion (in thY) tor batope. other Van lodus. with hen bme Vmreaerth' 15 rw'ss, ~k s a bm 9%

4 he tll ~nlo~e ~1hyin"P woolwI.

v N

'e i17r$

NORTH ANNA.- UNIT 1 1-.2 Anw nwu Mm No.46,41'34, 181 p~

ct, c 20ý ft I

i (4t, I q

4

rabJmflPJ tComin,,.4qA

a.

Capable 01 being closed by an OPE system.* or

b.

Closed by manual valves, blind flanges, in their closed posiems, except for yam control as permitted by Specdaa~n3 3LE~raln"Wnh autnomatic isolation %.

or deactivaed autorrtic valves seac 18that are open under admninistrative 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 0ew oriOnrgs/

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 l supesion of CORE ALTERATION shall nlot precb~t clentAbn of fwovemnein t Of & on;=Wn Wo a Wa%

conservative position.

tC)RF OPFRATINtM LIMITS REPQRT 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 ceJ Pue 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 m the re a~or oar3 t u thtirme 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

"I NORTH ANNA - UNIT 2 1-2 Anandiniet~ No. 2:3.3c, 162 2~~47..

V2e 1,q if-4-29 PAT-3bm

(-(

fi5,0;_f

-I A

MEmbirnONS (Co LLIý Sze 04

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 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. DOC A.8 is incorrect. CTS 1.6.5 states that 'The sealing mechanism associated with each penetration (e.g., welds, bellows, or O-rings) is OPERABLE." STS B3.6.1.1 Bases - BACKGROUND has a similar statement defining the leaktight barrier.

ITS B3.6.1.1 Bases - BACKGROUND deletes this statement based on changes made to the ISTS (Bases JFD 2). Since CTS 1.6.5 is contained in the CTS and no changes to the ISTS were made with regards to this item, it needs to be included in ITS B3.6.1.1 Bases - BACKGROUND. Comment: Revise ITS B3.6.1.1 Bases - BACKGROUND to include CTS 1.6.5 or provide additional discussion and justification for its deletion based on system design, operational constraints, or current licensing basis.

Response: The Company will take the action proposed in the Comment. CTS 1.6.5 is marked as part of ITS 3.6.3. Requirements for CTS 1.6.5 are deleted and justified by DOC L.14. 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 previous response is modified. CTS 1.6.5 is relocated to the ITS 3.6.1 Bases instead of being deleted. The ITS 3.6.1 CTS markup is revised and DOC LA.2 is added to document the relocation of CTS 1.6.5 to the 3.6.1 Bases. The ITS 3.6.3 CTS markup is revised and ITS 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 SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a challenge to containment OPERABILITY from high pressures and temperatures are a LOCA, I3.6.1-4 a steam line break, and a rod ejection accident (REA)

R1 (Ref. 2). In addition, release of significant fission product radioactivity within containment can occur from a 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 (Ref. 3). This leakage rate, used to evaluate offsite doses 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)

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

Containment B

Es 3.6.1 BASES BACKGROUND (continued)

2.

closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions, except as provided in 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

d.

The GrgaffU3e sealing mechanism associated with neLrtio is OPER.ABVL.

e

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

The OBAs that result in a challenge to containment DfromAhih pressures and temperatures are a (esOo ota om LC9 a steam line break, and a r6o ejection accen J )

Ref. 2).

n addition, rele significant fission product radioactivity within containment can occur from a 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 ;ont*?i*nt was designed with an allowable leakage rate of f

of containment air weight per day (Ref. 3).

This leakage rate. used to evaluate offsite doses resulting from accidents, is defined in S10 CFR 50. A ndix (Ref. 1), as L,: the maximum owa e containment leakage rate at the calculated peak containme internal pressure (P ) resulting from the limitin D The allowable leakage rate represented by L.

Je-n a

/OCA forms t asis for the acceptance criteria imposed on all con ain nt leakage rate testing.

L, is assumed t be 0.IUper day in the safe-y" alyses at P, = "4.4] psig (Re.

r3).eqcog% o-*r'

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

(continued)

B 3.6-12 WOG STS I

Aftl Pev. 1k Rev 1, 04/07/95

IT -5 3, 6,(

4-22-94

,q'iVbjC

.l TT5 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 rCQRF Ml TERATION 1.8 CORE ALTERATION SW be fte movetvert or nu*okdn of arm co~gam W06 the i roamor pressurs vena~l with the vases I had nren~vd ari Wue in 1w wesal. wspernso 01 CORE ALTERATION OWai not prockJde rWtbn ofl m WmwflWU 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 in hkvbiWJ upemuiobwm

!DORF FOI JIVAI FNT I1-12 1.10 The DOSE EOUIVALBJT 1-131 shaDbe tiulrwomrallonf 1.131 (Noowji.*rm whcbrw~

woui WOUV th UNUia m~~o~

C Vo do"

.as the ariat

&W b w=

t

xof 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 Ke=

jf.AVIFFRAG DIINTE-GAT)ON FNERtlY 11.11

?Vstie be tie average twe*gtod hInppronloplnictie c i=rMrvalb sof a rdr in the re &=x cookaft at the Umi of wrpig) ot Vw sma of t Vsaverage bew arid gammaa oriurpws per dilrWnVatlon (in M.V) llo b~owpes ottu tan'"

&w, with hag boss gr~amerVtar 1.0 Drr-,=ý

ý V

... =czý NORTH ANNA.- UNIT' I 1 -2 Al Wiwrus No..34,48734 1 81 Pa c 50 1.6.2 1.6U Rk3 3.b.2-z R A1 3,-1 I

i

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 act aSpeclation3.6.1.2 aMd 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 AT 3:b.

Lpump~ Seas.

roauw jol 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 in the 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 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 brnfts "laf be determined tor each re~ad Cycle in accrclarce with Speclkalin 6.9.1.7 P11M ope ratin within thes operalarag hnftis uaddressd in ffx*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 MSe hec~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 hin able 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 rnkkigi,~at lsat95% 1 te toal on-idin a~ivnyh the Coolant.

IT5 d, o NORTH ANNA.- UNIT 2 1-2 Amnmwa~wNo..3: s.331 62 F-0,.1.

S,,ý 5

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 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 action expeditiously. Containment structural integrity problems once confirmed are unlikely 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 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time frame is 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 LA. 1 (Type 2 - Removing Descriptions of System Operation) CTS 1.6 states, "CONTAINMENT INTEGRITY shall exist when:... 1.6.2 All equipment hatches are closed and sealed." 3.6.1 states, "Containment shall be OPERABLE." This changes the CTS by moving the reference to the equipment hatch being closed to the Bases.

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 protection of public health and safety. The ITS still retains the requirement to perform required visual inspections and leakage rate testing in accordance with the Containment Leakage Rate Testing Program in accordance with 10 CFR 50 Appendix J, Part B, which would provide verification that the equipment hatch is closed. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system operation is being removed from the Technical Specifications.

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

DISCUSSION OF CHANGES ITS 3.6.1, CONTAINMENT each penetration (e.g. welds, bellows, or O-rings) is OPERABLE." This changes the CTS by moving the 1.6.1 and 1.6.5 portions of the definition to the 3.6.1 Bases.

X0AIt 30I-1 The removal of these details, which are related to system operation, from the 3.--3 Technical Specifications is acceptable because this type of information is not 014 necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the containment to be OPERABLE and the relocated material describes aspects of OPERABILITY. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled.

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

LESS RESTRICTIVE CHANGES L. I (Category I - Relaxation of LCO Requirements) CTS 1.6 states, "CONTAINMENT INTEGRITY shall exist when:... 1.6.2 All equipment hatches are closed and sealed."

3.6.3 states, "Each containment isolation valve shall be OPERABLE." This changes the CTS by not including an explicit reference to sealing the equipment hatches. The j

I change associated with moving the reference to the equipment hatch to the Bases is

.3..

addressed by DOC LA. 1.

The purpose of CTS 1.6.2 is to help provide assurance that the equipment hatches can perform their safety function. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The Containment Leakage Rate Testing Program requires testing be performed in accordance with 10 CFR 50 Appendix J, Part B, requiring the containment isolation valves, including the equipment hatch, is OPERABLE, but there is no specific mention of sealing the equipment hatches. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

North Anna Units 1 and 2 Page 4 Revision 14

1-rs 5,.

A nJmONS (Conhirmjed

4-22-94 Capable of being osdby an OPERABLE wrUakiMMn autornatc isolaln valve sysPem. or Closed by mamiua valves. blind Wipes, or deactirmed auorwuzc valvft ecure in their WN4s Of' valvesep VW~~a aws o"e AAI.a-h f,~r AT~

I TT5 s9 3.b. 3 1 R 3.3

'93b3A 1.e.2 Ja po@e.e hace are clse and seld 1.9.3 mwwg a0 QkGbc

3.

OPEATL puria to p4mon 1.6A u

~e~

1.6.

~ 5~da~d wi

~

S 34Ws.2 an@Iw m -rng)

)

1.7 CONTROLLED LEAKAGE "la be tha seal watrtow suoe a

o 1w f reator CDOM 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 o a sormwlan%

wnservam e Psiton Q-QRF OPERATMN LI UMT REPORT 1.9 The CORE OPEPLAT0NG LIMITS REPORT Iste 1wuni-spee doajrem tha pmvie wre operalk ing toe f

the uvrn" "prating relod 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 "ap ration wifttn thes opeutrig WeTda Im edchs -c' in inKvbjaJ speoftabaow 1.10 The DOSE EOUIVALENT 1.131 shial be OWt awnoruvulon of 1,-131 1nm~omaiewpgano wtK1h alone would puo~.i the sm "w Vhrow 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 "1ha be "w arverage tw*VtWludin piopwlon t 1we wor-anwuat onf eac redt41~d inm rhe enw w obia ad the Wmn of san*I) of 1w sum of Me aermage bets and wmm energies per disintegration (in 11eV) be imcomoe, other than Ior di wati haMll~espremo Ian 1$ rrw".es mel~ki up0 atlw 95% of the WWI nwon.wI wvky in the voolwL 1-2 NORTH ANNA - UNIT I b.3:

3.

i AvvrwndnwrusPb.3,4.,.346 9181 P,6 I.

{b..

('1O moe 0%

ncr'Nmcws (Continued)

ý,e "Mar. &W1ALXCM.Qmj-="

i

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

C~pabe of beinig closed by an1 OPERABLE conuainflITent Am11nt01tc isolationl valve

~

) system, or b.~~V k~!D s

rdaptivaled aulornatic valves secured interlsdoin

'e-zx for valves that are opt rative 1.6.2 ANl 0Q.lpWI and-seaC)"7-

ýEa~ch ar ilod i OP ERABýLE prun oSei tý.

ýZ-4-'

1.7 CONTROLLED LEAKAGE ShahE be that sea) water flow ~idto the rnacae c~olan!

purnp saws.

AlR ATERATION 1.5 CORE ALTERATION "Ial be the n~wetflt3 or rnardputaton of any CnonertM wittln the rea=o pressure vessel with the vessel head frswvved and tuel in the VesseL Iuspersvnof CORE ALTERATION Shall rot pfSmbjds cornilelort of tixy. rme of a cornporomt to a &ate conservalsve posaton.

CQRE OPERATING? UIrTS REPORT 1.9 The CORE OPERATING LIMITS REPORT Is the uni-Wjecki6 doamewm that prvvkes core operating Wrirts tor the current operati~ng reload cycle. These cycwespecic cOSorerating Uinits Shah be OEM,,n*ie tor each reload cycle in accrdance with SpecNtaton 6.9.1.7 Plant cpe ration within these ope ratig linfts a addressed in wdwxkWa spe~casiomjL DQSF FOtJIVAI ENT l1-11 1.10 The DOSE EOUIVALENT 1-131 81hall bethalC centratuuono 01-131 (mirmocriesavrm) which alone would proawc the sarne thyroid dose as the QWantl~y and htoupic rix nu ol 1131, I 132, 1.133. 3-134 and 1-135 actually present. The thyroid dose corvwenion tswor used tar tuis Wm L--

.. 9

.+/-

m.

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m.

Im a

I w L UI r

I u

Power arid rest uiea~ %MWu Ef-AVFRACnE ptiTNTFGRAsmou ENRgny 1.1

'E shah be the average tweighied in pboportion to the concntration of each radionujclide in the reamor coolant ait the t

smie 0 arqn) of thm sum of the atvrage beta and anana

.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 12L

-J

Ai 3.I-Z Ri K

T5 I'0-T NOR~h NNA-UNT 2 1 - 2Anwnxnes No3.4.2O,. 162 (I

ree rn ý IWO IF or rmgs C.Ama demOn W-40

&M 00.000 1-

. L-MICUMMOn 01 Lnwjwww raCtM Wr NORTH ANNA - UNIT 2 1-2 e"' tý f4tv 68ýb

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

the assumptions of the accident analysis. This change is designated as less restrictive 3.C.2 I because less stringent Surveillance Requirements are being applied in the ITS than I

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 more isolation valves inoperable, maintain at least one isolation valve OPERABLE in 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 within the assumed limit. This change is acceptable because the Completion Time is 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 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 is 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 (Category 4 -Relaxation of Required Action) 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..

open, CTS 3.6.1.1 Action applies. That Action states, "Without primary 3.6.3-6 CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one lel#

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 Required Actions for systems made inoperable by containment isolation valves, and require entry into the applicable Conditions and Required Actions for LCO 3.6.1, "Containment," when leakage for a penetration flow path results in exceeding the Revision 14 North Anna Units 1 and 2 Revision 14 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 NRC RAI: STS SR 3.6.2.2 requires verifying only one door in the air lock will open at a time at a 6-month interval. The interval is modified in ITS SR 3.6.2.2 from 6 months to 24 months. This modification is in accordance with TSTF-17 Rev. 2; however, the Bases changes are not in accordance with TSTF-17 Rev. 2. Comment: Revise the ITS Bases to be in accordance with TSTF-1 7 Rev. 2 or justify the deviations.

Response: The Company will take the action proposed in the Comment. The sentence, "The 24 month Frequency for the interlock is justified based on generic operating experience." is added to the SR 3.6.2.2 Bases. Also, JFD 9 is added and the TSTF-17 insert is modified to justify how the TSTF was addressed.

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

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

OPERABILITY if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 24 month Frequency. The 24 month Frequency is also based on engineering judgment and is considered adequate given that the interlock is not challenged during use of the air lock.

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

2. UFSAR, Section 6.2.

3. UFSAR, Chapter 15.

Rev 14 (Draft 1), 01/10/02 North Anna Units 1 and 2 RAI 3.6.2-9 RI, R14 B 3.6.2-8

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

the retor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.

North Anna Units 1 and 2 Insert to Page B 3.6-27 Revision 14

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

However, the staff concludes that this specification needs to be retained in the North Anna ITS. Amendments 196 and 177 to the North Anna Unit 1 and Unit 2 TS respectively, dated February 9, 1996, implemented 10 CFR 50 Appendix J, Option B.

The amendment change approved a Containment Leakage Rate Testing Program based on 10 CFR 50 Appendix J, Option B that was outside of the CTS, and did not include this specification in that program, but retained it in CTS 4.6.1.1.d. Since this specification contained specific testing requirements not contained in 10 CFR 50 Appendix J, Option B, it should be retained in the ITS as an SR in ITS 3.6.3. The STS does contain an SR on purge valve leakage. TSTF 52 Rev. 3 did not remove or relocate the purge valve leakage SR (STS SR 3.6.3.7). In fact, STS SR 3.6.3.7 was retained because the testing requirements went beyond the test requirements of 10 CFR 50 Appendix J. This STS SR deals with leakage testing of purge valves with resilient seals. It would seem that CTS 4.6.1.1.d was retained because the valves had resilient seals, but this is not stated in CTS 4.6.1.1.d, the Bases for ITS 3.6.3, or in the DOCs and JFDs. If these valves do have resilient seals, then CTS 4.6.1.1.d needs to be retained in the ITS. Even if they do not have resilient seals, the specification needs to be retained because of the special testing requirements which go beyond the requirements of 10 CFR 50 Appendix J. Thus, STS SR 3.6.3.7 needs to be used or modified to reflect plant-specific testing requirements. Since this STS SR is being added to the ITS, an appropriate ACTION needs to be provided for when the SR is not met. This ACTION would be STS 3.6.3 ACTION D or E as modified by TSTF-207 Rev. 5 and any plant-specific requirements.

This may result in modifications/changes to CTS 3.6.1.1 ACTION. In addition, ITS 3.6.3 Conditions A and B will need to be revised to conform to TSTF-207, Rev. 5. Comment:

Revise the CTS/ITS markup to retain CTS 4.6.1.1.d and provide the appropriate discussions and justifications for all the changes associated with this SR retention.

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

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems 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, as modified and justified by JFD 10.

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

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

The shield building bypass related portions of ISTS ACTIONS A, B and D are not adopted because NAPS does not have a shield building.

The purge valve related portions of ISTS ACTIONS A, B and D are not adopted because the Required Actions and Completion Times for the purge valves are the same as for other containment isolation valves.

ISTS ACTION E is not adopted because the Required Actions are the same as those for ISTS ACTION A, except the Required Action E.1 and E.2 Completion times are 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and ISTS Required Action E.3 requires that ISTS SR 3.6.2.7 be performed once per [921 days for the resilient seal purge valves closed to comply with Required Action E.1. ISTS SR 3.6.2.7 will not be performed at NAPS.

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

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

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

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

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

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

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

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.

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

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

Containment Isolation 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO

3.6.3 APPLICABILITY

Each containment isolation valve shall be OPERABLE.

MODES 1, 2, 3, and 4.

ACTIONS NOTES ----------------

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

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

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

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

CONDITION REQUIRED ACTION COMPLETION TIME A. --------- NOTE ---------

A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AnlI 2nnlirVhlp to penetration flow path penetration flow paths with two or more containment isolation valves.

One or more penetration flow paths with one containment isolation valve inoperable for reasons other than Condition D.

by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

AND RAI 3.6.3-2 R14 (conti nued)

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

Containment Isolation Valves 3.6.3 ACTIONS CONDITION B.

NOTE------

Only applicable to penetration flow paths with two containment isolation valves.

One or more penetration flow paths with two containment isolation valves inoperable for reasons other than Condition D.

C. - --------

NOTE --------

Only applicable to penetration flow paths with only one containment isolation valve and a closed system.

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

REQUIRED ACTION B.1 C.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months RAI 3.6.3-2 R14 1RI3.6.3 R14 RAI 3.6.3-2 R14 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND (continued)

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

Containment Isolation Valves 3.6.3 ACTIONS CONDITION C. (continued)

D.

Purge valve penetration leakage not within limit.

E.

Required Action and associated Completion Time not met.

REQUIRED ACTION C.2 NOTES------

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 penetration flow path is isolated.

D.1 Restore leakage within limit.

E.1 Be in MODE 3.

AND E.2 Be in MODE 5.

-- I-COMPLETION TIME Once per 31 days 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 6 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months J

J ______________

Rev 14 (Draft 2), 01/31/02 North Anna Units I and 2 RAI R14 3.6.3-2 R14 13.6.3-2 R14 3.6.3-4

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."

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

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 leakage not within limit, the affected penetration flow path 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)

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

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 path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must 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 is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4.

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

Condition A has been modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two containment isolation valves. For penetration flow 13.6.3-2 paths with only one containment isolation valve and a closed R14 system, Condition C provides the appropriate actions.

Required Action A.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation areas and allows these devices to be verified closed by use of (continued)

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

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 be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. Therefore, the probability of misalignment of these devices once they have been verified to be in the proper position, is small.

B.1 With two containment isolation valves in one or more 3.6.3-2 penetration flow paths inoperable, except for purge valve R14 leakage not within limit, the affected penetration flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . 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 de-activated automatic valve, a closed manual 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 consistent with the ACTIONS of LCO 3.6.1. In the event the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative control and the 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 containment isolation valves. Condition A of this LCO R14 addresses the condition of one containment isolation valve inoperable in this type of penetration flow path.

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

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

RAI D.1 3.6.3-2

_____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 the penetration(s) that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time for purge valve penetration leakage is acceptable considering 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 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 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 required unit conditions from full power conditions in an 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 containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed.

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

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

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.

APPLICABILITY:

MODES 1. 2. 3. and 4.

ACTIONS S...

U-..

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

inch purge~valv* flow paths--may be unisolated intermittently under administrative controls.

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

3.

Enter applicable Conditions and Required Actons for sys made inoperable by containment isolation valves.

4.

Enter applicable Con tions d Required.Ac4ions of LCO 3.6.1.

"Containment," when leakagea results in exceeding the

Conalmet, w

ea a

.e 4

la

e.

overall containment ea age rate acceptance criteria.

t.....................

CONDITION REQUIRED ACTION COMPLETION TIME A..........

NOTE.........

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

.i.........

automatic valve, "closed manual valve, One or more blind flange. or penetration flow paths check valve with flow with one containment through the valve isolation valve secured.

..ino erable exce for (purge y e or i~~elo AND (continued) 3.6-B WOG STS 3.'. I 3.b.A -1 i A

n I7 Rev 1. 04/07/95

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

.6.3 NEW~~A 3.6-9 WOG STS Rev 1. 04/07/95 ACTIONS C

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2 NO Isolation devices in

'high radiation areas S4*to(JEU'fLL e

It__s re

.may be verified by

-/ckeAllseade Jar t'i-h r L use of administrative T51

.J a~xare-ma* ý& v,'ow k.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 B.......... NOTE.........

B.1 Isolate the affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to penetration flow path penetration flow paths by use of at least with tworcontainment one closed and isolatio valves.

de-activated automatic valve, closed manual valve.

One or more or blind flange.

TS-TF-ff 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)

-1 7'L IAt (D

Containment Isolation Valves WtmospOEric C-uatmo rl.,,

o serD, a-,

Dual_

J.0-5 CT5 ACTIONS (continued)

CONDITION AA,-

C. -

C NOTE.........

Only applicable to A-dfo.(,

penetration flow paths with only one containment isolation valve and a closed system.

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

NEJW

/orked3ade~v riI 39xfr&&

.SCC~-,SA Lbe* tlf:AAJL

5ecLJ4 £Vtifl 4

l

/eIl i'&~~

~~

-fJhf~law 1~$S REQUIRED ACTION COMPLETION TIME C.1 Isolate the affected renetration flow path yuse of at least one closed and de-activated automatic valve, closed manual valve.

or blind flange.

AMn C.

........- NO~t -T0------

C'2 (

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

Verify the affected penetration flow path is isolated.

hours Once per 3 days

-L.

I E. one or more penetration flo paths with o or more contai nt purge valv not within pu e valve leakage iits.

.i Isolate the aff ted penetration f w path by ue of at east one 91 ose and de-adtiv d

automat

valve.

close manual valve.

or b nd fl angz AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (citn 3.6-10 Rev 1. 04/07/95 WOG STS 0

757f 3

.

I" I

I

Containment isolation vavs(Atmosph~prc.

3.6-11 Rev 1. 04/07/95 (JT$

Ac4;b

0,P

)..37 PiL o0.

WOG STS

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 ¶5-..

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

le

4. Not used.

? O

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 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 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 also consistent with the current licensing basis.

7. ISTS 3.6.3 ACTION E is not adopted. ISTS 3.6.3 ACTION D is adopted and revised.

94.1 The STS Reviewer's Note added by TSTF-207, Rev. 5 states that Condition E is applicable to purge valve leakage which can be measured separately for each purge valve.

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

North Anna Units 1 and 2 Page 1 Revision 14

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

I

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

and Condition B, is not adopted. At NAPS, only two valves in each penetration

?.3..

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

opened in MODES 1, 2, 3 and 4, and do not automatically close. The CTS treat the purge

ýC3-4 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.

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

Containment IsolationValve (Atmos ic.

uDual BASES (continued)

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 esta lis ing the containment boundary during a DBA. I-e ar ikrwts~se; 5(). 146u %. I The au omatic ower operated isolation a ves are required to have isolation ti s within limit and to actuate on an automatic isol tion ignal.

The inch purge valves must

-;Ati cig s d ortnaVe Diocks inS preven u

openi ng.

Blck urLvle(aoaut on an~tm s

a.

va yes covere y t is LCO are listed along with t eir associated stroke tims in theoB_

(Ref. 2).

A_ _

I 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 flanges are in place. and closed systems are intact.

These passive isolation valves/devices are those listed in Reference Purge valve ith resilient seals a

cOna te c 2ntn S must meet additiona l

age requirements.

The other containment isolation 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.

0 D

-R kF.

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."

(continued)

£*-"

A~Rev

1. 04/07/95 WOG STS

/2CXZH LCO

)

Containment Isolation Valve r(At-osp hnc u

ice des

a Dual BASES (continued)

)

-bl Aod'o i

u penetration flow ACTIONS The ACTIONS are mo y a te all ing penetration flow paths, except forý []..inch' purge Valv.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 Jthis way. the penetration can be rapidly isolated when a 46 A

-SC nee ation is indicated.

Due to the r\\3 fjO~

the containmen ur line cn fr an fc clcs,.re friwfhr OP-'

that os n

ion ex aus irect Y from the 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 r-wr4cOA,5 n/e ra i flow pat may b ned to effect re rs to an 0j 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 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.

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

In the event the rock leakage results in exceeding the 0

1, 11c 5

ii overall containment leakage rate' Note 4 directs entry into

@9 th appl icab -e---onditions and Required Actions of LCO 3.6.1.

A.1 and A.2 In the event one containment isolation valve in one or more enetrat,..flo aths is inoperable 4xcept for purge valve or-*-*i*'[d bun*as leakage not within limit* the "affecte penetration flow path 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 (continued)

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

BASES ACTIONS A.1 and A,2 (continued) failure.

Isolation barriers that meet this -criterion are a closed and de.activated automatic containment isolation valve, a closed manual valve, a bl0ind flange, c

hck (k

valve with flow through the valve secured.

For a 01 penetration flow path isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment.

Required Action A.1 must 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 is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1. 2. 3. and 4.

For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time and that have been isolated in accordance with Required Action A.1. the affected penetration flow paths must be verified to be isolated on a periodic basis.

This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur.

This Required Action does not require any testing or device manipulation.

Rather. it involves verification, through a system walkdown. that those 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 devices inside containment, the time period specified as

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

Condit-ion A has been modified by a Note indicating that this Condition is only applicable to those penetration flow paths 31-3-2 ccr wi wo ontainment isolation valves.

For penetration flow paths with only one containment isolation valve and a closed system. Condition C provides the appropriate actions.

(continued)

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

Containment Isolation Vale Aetý ericD.

u batmosp i c.-ce dond

.aer B 3.6.3 BASES ACTIONS A.1 and A.2 (continued) e I Required Action A.2 is modified byf Notea applies to isolation devices located in high-radiation areas and allows NoL-2. applhes -I oLt*;A these devices to be verified closed by use of administrative

-STP Jev; ir&-t. arfe Iockel 1 means.

Allowing verification by administrative means is

_ale D~L or efiae-wia EcareJ considered acceptable, since access to these areas is n p*tii a*

4 e typically restricted. _ Therefore, the probability of

Idt,.

h Ge werf,;.J_

Clsed misa ignment of these devices once they have been verified bq ufof.imini.trative_

to be in the proper position, is small.

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

,ion mut include the use of at least one isolation U

%te~

are htcno be adversely affecte.d by a singl acie failure.

Isolation barriers that meet this criterion are closed and de-activated automatic valve, a closed manual 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 consistent with the ACTIONS of LCO 3.6.1.

In the event the affected penetration is isolated in accordance with Required Action B.i, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2. which remains in effect.

This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated.

The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative control and the probability of their misalignment is low.

7.o e

A~ 7 r.",n Condition B is modified by a Note indicating this ConditioitP,---1,-

is only applicable to penetration flow paths with two 1 1)0 containment isolation valves.

Condition A of this LCO addresses the condition of one containment isolation valve inoperable in this type of penetration flow path.

(continued)

B 3.6-35 WOG STS

Q1

Rev 1. 04/07/95

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

uba ms c. c ;pLense. and Dual B5 J..

BASES ACTIONS G2.

(, eVavfev 4 T (continued)ag with the jibui-14rn ass leakage rate,,t within limit, the assumptions of the safety analyses. are Therefore, the leakage must be restored to within limit i

Restoration can be accomplished by iso ating-the penetration(s) that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve. or blind flange.

When a penetration is isolated the leakage rate for the isolated 7penetration is assumed to be the actual pathway leakage through the isolation device.

If two isolation devices are r

jused to isolate the penetration. the leakage rate is assumed to be the lesser actual pathwa leakaq of the two devices.

he..hour pe*e ime.. is r sonable considerin he t

time requ, ed to restore te akage by isolatin

./-.

Co'7,O penetr on(s) and the re tve importance of ondary

~LA e

.3LM cant.

nt bypass lea e to the overall c ainment 14" v.u tion.

I a-"

tILL (e4 3.11.7 Tlo

."o~

Rev 1. 04/07/95 WOG ScSBt3.6e37 E.,.L*E.2. and.E.3 In the event one or e containment purge valves i one or more penetration paths are not within the p valve leakage limits, rge valve leakage must be re red to within limits rthe affected penetration f path must be isolated.

method of isolation must y the use of at least onee solation barrier that canno adversely affect by a single active failure.

solation barriers that t this criterion are a ed and de-activat d a

atic valve, closed manual Ve. or blind flange.

A 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.

I n 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 fo

wnanacdn, hich are no I ger capable of being

ýol wing a(continued)w 11.a b

24 0

,ýeS O eld

,"a B 3.6-37 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 should an event occur.

his Required Action does not require any testing o valve manipulation.

Rather.,t involves verificati

, through a system walkdown hat those isolation devices utside containment capable being mispositioned a in the correct position.

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

For the contaiet pur valve with resilient seal that is isolated in accordanp with Required A.tio~n E.1. SR 3.6.3.

mutb eforme tleast once every[9Jdy.Ti must be perfond*~

_~s

)s4*

assures that degedto of the resilient seal is det ed and confirms It t theleakage'rate of the containme purge valve does increase during the time the penettins vallve does nehe t

~ion is._

isol ated.

he normal Frequency for SR 3. 6.37 84 days. is based on n NRC initiative-,

i Ref.'. 3;).

Since re reliance is placed on a single ye while in this ondition-it is prudent to perfo he SR more often.

The fore, a Frequency of once per [9 days was chosen and h

been shown to be acceptable bas on operating e

rience.

/

/-if the Required Actions and associated Completion Times are3

/

o me,

_must be brought to a MODE in which the*

!J 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 to MODE 5

(/*.**"

)

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

The allowed Completion Times are based on operating experience, to reach the required(

conditions from ful1 power conditions in an orderly manner and without challenging _T systems.

(continued)

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

(D CONTAINMENT SYSTEMS

.;/A CONTAINMENT ISC 177S 3..3 4-22-94 3LATION VALVES LIMITING CONDmQN FOR OPEATION 3.6.3.1 Each containment isolation valve shall be OPERABLE.*

I APpLICABILrT'Y:

MODES 1,2,3. and 4.

A C T IO N:.

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 is t 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 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 .,,

SURVEILLANCE REQUIREMENTS

/ViseA 0 0-

.c r c4f *j 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 is grer than or equal to 1.2 p but es than 5.0 Psi&.

t______

_____late__

A"'

L.'e.M e.d

yet

opened on an intermittent basis under NORTH ANNA UNIT-1 3/4 6-15

- Ii Amenldment No.181

/4,/6 Al:

L3-l7 IRAI 3_

LIMITING CONDmON FOR OPERATION I

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 4-22-94 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

" so a

affeced penetration withir J e us ofatI one deactivated automatic valve secure in lioiationposztior A

A.

c.

Isolate each affected penetration withn(ný)hours by use of at least AT C+on A.' Ione o

rnrual valve 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

SURVEILLANCE REOUIREMENTS

/

oS,-

Ac 7on,>,v.s 4,..2_

011' lit Al 13,,,-

\\

\\ it 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 9r1e s assoclated actuator, cornjil or power circit by pertoip~nce of the applicable

,cycling te t~nd verification otsoiston ti.

may be opened on an intermittent basis under 0

I.

(2)115 NORTH ANNA UNIT-2 Ad.'

O.'-I-A*-roa I~A NVoit I W4 6 ý-l 44 Amendment No. 162

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

' Dj-"V1ýe) i,, e 3 e r A ar 5 foL bi lc--

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES specified actions. ITS 3.6.3 does not state the requirement to restore an inoperable isolation valve to OPERABLE status, but includes other Actions to take within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS LCO 3.0.2 states, "If the LCO is met or no longer applicable prior to the expiration of the specified Completion time(s), completion of the Required Actions(s) is not required unless otherwise stated." This changes CTS by including the requirement as part of LCO 3.0.2, rather than explicitly stating the allowance.

This change is acceptable because it retains an existing allowance in ITS format with ITS usage rules. This change is designated as administrative because it does not result in technical changes to the CTS.

A.5 CTS 3.6.3.1 and CTS 3.6.5.1 do not include any Condition and Required Actions for one or more penetration flow paths with two containment isolation valves inoperable.

CTS 3.0.3 would be entered for this Condition. ITS 3.6.3 Condition B states, "One or more penetration flow paths with two containment isolation valves inoperable." ITS Required Action B.1 states, "Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind PA-1 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 the unit be placed in MODE 3 7

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 and associated Completion Time is not met. This changes CTS by stating the Actions to be taken for two containment isolation valves inoperable, rather than relying on CTS 3.0.3, which contains the same Completion Times for placing the unit outside its MODE of Applicability.

This change is acceptable because it places CTS 3.0.3 requirements in ITS format.

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

A.6 CTS 3.6.3.1 Action states, "The provisions of Specification 3.0.4 do not apply." CTS 3.0.4 states, "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provision contained in the ACTION statements unless otherwise excepted." ITS 3.6.2 does not contain the exception to ITS 3.0.4.

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

This change is considered acceptable because LCO 3.0.4 is changed in ITS such that the NOTE is not required to retain the same CTS requirement. ITS 3.6.2 Actions allow continued operation for an unlimited period of time, which together with ITS 3.0.4 result in the same technical requirements as the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

North Anna Units 1 and 2 Page 2 Revision 14

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES A.10 CTS 4.6.3.1.1.a requires testing of each containment isolation valve that is a weight or spring loaded check valve testable during unit operation every 92 days. The ITS does not contain this Surveillance. This changes the CTS by eliminating this Surveillance.

This change is acceptable because the technical requirements have not changed.

North Anna does not contain any containment isolation valves that are weight or spring loaded check valves which are testable during unit operation. Therefore, this surveillance is never performed. This change is designated as administrative because it does not result in technical changes to the CTS.

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

the penetration be isolated within one hour, or Condition E is entered, requiring the I

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 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In a penetration flow path with one containment isolation valve and a closed system, where the containment isolation valve and the closed system were not capable of performing the isolation function, ITS LCO 3.0.3 would be entered. This changes CTS by incorporating the concept of assuring that the second means of containment isolation for a penetration flow path is OPERABLE into the Conditions and Required Actions associated with ITS 3.6.3.

This change is acceptable because when one means of isolating a containment flow path is inoperable, the other must be OPERABLE, or the ITS requires Required Actions be taken for two inoperable means of isolating a containment flow path, rather than allowing the Completion Times associated with one inoperable means of isolating a containment flow path. This retains the CTS 3.6.3.1 concept of maintaining at least one isolation valve OPERABLE in each affected penetration that is open when one or more isolation valves are inoperable. This change is designated as administrative because it does not result in technical changes to the CTS.

A.12 CTS 4.6.1.1.d states, "Each time containment integrity is established after vacuum has tA If been broken by pressure testing the butterfly isolation valves in the containment purge 63

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

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES misinterpreting the requirements of the Surveillance Requirement while maintaining Pe41 the assumptions of the accident analysis. This change is designated as less restrictive 3., 3.2 I because less stringent Surveillance Requirements are being applied in the ITS than t I were applied in the CTS.

te*f L.14 Not used.

L.15 (Category 3 - Relaxation of Completion Time) CTS 3.6.3.1 states that with one or more isolation valves inoperable, maintain at least one isolation valve OPERABLE in Q41 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.(-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 hoa 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 within the assumed limit. This change is acceptable because the Completion Time is 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 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 is 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 (Category 4 - Relaxation of Required Action) CTS 4.6.1.1.a requires verification that 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..

open, CTS 3.6.1.1 Action applies. That Action states, "Without primary 3.6.3-6 CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one elm 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 Required Actions for systems made inoperable by containment isolation valves, and require entry into the applicable Conditions and Required Actions for LCO 3.6.1, "Containment," when leakage for a penetration flow path results in exceeding the North Anna Units 1 and 2 Page 16 Revision 14

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 required to be closed is found to be open and the ITS 3.6.3 ACTIONS are applied in this

NAPS Responses to NRC Requests for Additional Information ITS Section 3.6, Containment Systems circumstance. DOC L.16 is added to document the change. DOC L.16 also addresses the application of ITS 3.6.3 ACTION Notes 2, 3, and 4 to the requirements of CTS 3.6.1.1. These changes also respond to the concern in RAI 3.6.3-6.

J7,-

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

"*.Th CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY-MODES 1, 2, 3, and 4 mr OTp0.00167 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 .

SURVEILLANCE REQUIREMENTS r

4..11 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a.

At least once per 31 days by verifying that all penetrations not capable of being S-K5 closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves,blind flanges, or deactivated S54

3. C3.-

automatic valves, secured in their positions,!except for valves tha re o en under administrative control as permitted by Specification 3.6.3.1. e44~t-Cu -Aor0

b.

By verifying that each containment airlIocM is-OPERABLE per Specification f*

3.6.1.3.

c.

After each closing of the equipmet hatch, by leak rate testing the eqluipmerit hatch seals, with gas at P, greater than or equal to 44.1 psig. Results shall be evaluated against the criteria of Specification 3.6.1.2.b as required by 10 CFR 50, Appendix 3, Option B, as modified by approved exemptions, and in accordance with the guidelines contained in Regulatory Guide 1.163, dated September 1995.

d.

onirln ite.

t tablished ter vacuum has been broken by pressure testing the(

isolation valves in the containment purge lines and the containment vacu ejecto l-inetl'e**,

Except valves, blind flan es, and deactivated automatic valves which are located inside the containment and are ocked sealed or otherwise sealed in the closed osition.

hese penetrations shall be verifie c ose unng each COLD SHUTDOWN except that such 5 3..' 6.3 2

/

surveillance need not be performed more often -an onc NORTH ANNA - UNIT 1 3/46-1 Amendment No. 44447-4,41 R3 I-T

\\5,o/

atu.11

GC 4

T7-S 3. 6-3 02-09-96 CONTAINMENT SYSTEMS CONTAINMENT CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY:

MODES 1,2, 3, and 4 ACTION;:

o our or e 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 .

SURVEILLANCE REQUIREMENTS

4. 6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a.

At least once per 31 days by verifying that all penetrations* not capable of being A

3 1closed by OPERABLE containment automatic isolation valves and required to be 109..r closed during accident conditions are closed by valves, blind flanges, or deactivated

6v_,

33.-j.

automatic valves, secured in their positions, except for valvesrt are o en unde 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.

c.

A ter each closing of the equipment hatch, by leak rate testing the equipment hatchh seals, with gas at Pa, greater than or equal to 44.1 psig. Results shall be evaluated against the criteria of Specification 3.6.1.2.b as required by 10 CFR 50, Appendixe J, Option B, as modified by approved exemptions, and in accordance with thee uidelines contained in Regulatory Guide 1.163 dated September 1995.

593.3.-01

d.

c ontain ite nt es i after vacuum has been broken by pressure testing thes(*

isolation valves in the containment purge lines and the containmen cuurp jctc i

Except valves, blind flang and deactivated automatic valves which are located inside the containment and ar ocked sealed or otherwise sealed in the closed position.

Trh--e,,

penetr sshall be Verified closed during each COLD SHUTDOWN except tat suc,/

5*,3

,- }-ae need notbe performed more often than once per 92 days...

LNORTH ANNA - UNST 2 3/46-1 Amendment No. 99-454462 Sle 3, (,-.2 5D1D

(.ii7

/

KI 3,ý t-z

!k Lj.

3/4.6 314-6.1 I

. ktv 14

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

[

4T the assumptions of the accident analysis. This change is designated as less restrictive 3 3,0'-- I because less stringent Surveillance Requirements are being applied in the ITS than j

I were applied in the CTS.

L.14 Not used.

L.15 (Category 3 - Relaxation of Completion Time) CTS 3.6.3.1 states that with one or more isolation valves inoperable, maintain at least one isolation valve OPERABLE in Q#7 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.-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 t

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 within the assumed limit. This change is acceptable because the Completion Time is 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 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 is 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.

I L.16 (Category 4 - Relaxation of Required Action) CTS 4.6.1.1.a requires verification that 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..,

open, CTS 3.6.1.1 Action applies. That Action states, "Without primary 3.6-3 CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one le of 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 Required Actions for systems made inoperable by containment isolation valves, and require entry into the applicable Conditions and Required Actions for LCO 3.6.1, "Containment," when leakage for a penetration flow path results in exceeding the North Anna Units 1 and 2 Page 16 Revision 14

DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES overall containment leakage rate acceptance criteria. This changes the CTS by 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 flow path affected by an inoperable non-automatic containment isolation valve, and allowing continued operation with an inoperable non-automatic containment isolation valve. This also changes the CTS by allowing separate condition entry for each penetration flow path with an inoperable non-automatic containment isolation valve, requiring entry into the applicable Conditions and Required Actions for systems made inoperable by inoperable non-automatic containment isolation valves, and requiring entry into the applicable Conditions and Required Actions for LCO 3.6.1, "Containment," when leakage through a penetration flow path due to an inoperable non-automatic containment isolation valve results in exceeding the overall containment leakage rate acceptance criteria.

The purpose of CTS 3.6.1.1 Actions is to ensure that overall containment leakage rate does not exceed the accident analysis assumptions. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. This change makes the actions for an inoperable non-automatic containment isolation valve consistent with the actions for all other types of containment isolation valves and ensures that leakage through a penetration flow path affected by an inoperable non-automatic containment isolation valve is isolated. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

North Anna Units 1 and 2 Page 17 Revision 14

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

Response: The Company does not agree with the action recommended in the Comment. The Company does not agree that this is a Less Restrictive change. 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 the valves are allowed to be inoperable for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

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 required to be closed is found to be open and the ITS 3.6.3 ACTIONS are applied in this circumstance. DOC L.1 6 is added to document the change. DOC L.1 6 also addresses the application of ITS 3.6.3 ACTION Note 2 to the requirements of CTS 3.6.1.1.

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

This reasoning is carried over to changes made to ITS B3.6.3 Bases - BACKGROUND and the associated Bases JFD 7. STS B3.6.3 - BACKGROUND states the following:

"Check valves, or other automatic valves..." ITS B3.6.3 Bases - BACKGROUND deletes the words "Check valves, or other" by Bases JFD 7. The justification states that check valves are not considered active devices. The staff's position is that check valves, when used as CIVs, are considered as automatic valves and thus are active devices. STS 3.6.3 Bases - BACKGROUND states this position and the discussion in STS B3.6.3 Bases - LCO reaffirms it when it differentiates between automatic power-operated isolation valves and check valves. The Bases for this position can be found in 10 CFR 50 Appendix A, General Design Criteria 55, 56, and 57, which state that check valves may not be used as one of the automatic isolation valves for certain types of penetrations. Thus the staff finds these changes unacceptable. In addition, the change made in ITS SR 3.6.3.4 is considered generic and beyond the scope of review for this conversion. Comment: Delete these changes.

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

ITS 3.6.3 JFD 4 is modified to state that for functional purposes, check valves are active or automatic devices, but do not receive an actuation signal. Adding the term "power operated" in ISTS SR 3.6.3.8 clarifies that only power-operated valves receive an actuation signal, and the automatic function of check valves is verified as part of ISTS SR 3.6.3.9.

ITS 3.6.3 Bases JFD 7 is modified to explain that consistent with Information Report SECY-77-439, dated August 17, 1977, "Check valves are classified as active components for the purposes of functional specification, inservice inspection, testing, and valve design (re: Regulatory Guide 1.146). Check valves are classified as passive components for the purposes of single failure and system design." The reference in the ISTS 3.6.3 Bases that is deleted is part of a discussion that addresses failures of automatic valves for the purposes of single failure, which is not that case for check valves at NAPS.

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

Additional Response: Based on verbal comments from the NRC, the portions of the previous response marked with an asterisk are modified. The revisions to ITS JFD 4 and Bases JFD 7 discussed in the response were not provided in the updated pages. The revised pages are provided.

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

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.3.5 Verify each automatic containment isolation valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

SR 3.6.3.6 Cycle each weight or spring loaded check 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 < 1.2 psid and opens when the differential pressure in the direction of flow is -

1.2 psid and < 5.0 psid.

FREQUENCY 18 months 18 months Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2 RAI 3.6.3-2 RAI 3.6.1-5 Ri RAI 3.6.3-12 R14 RAI 3.6.3-2 RAI 3.6.1-5 Ri 3.6.3-6

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.3.5 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic power operated containment isolation valve will actuate to its isolation position on a containment isolation signal. Check valves which are containment isolation valves are not considered automatic valves for the purpose of this Surveillance as they do not receive a containment isolation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

RAI 3.6.3-2 RAI I3.

RI RAI 3.6.3-12 R14 SR 3.6.3.6 13.6.3-2 RAI 3.6.1-5 The check valves that serve a containment isolation function RAI are weight or spring loaded to provide positive closure in the direction of flow. This ensures that these check valves will remain closed when the inside containment atmosphere returns to subatmospheric conditions following a DBA.

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

REFERENCES

1. UFSAR, Chapter 15.

2. Technical Requirements Manual.

3. Standard Review Plan 6.2.4.

4. UFSAR, Section 6.2.4.2.

RAI 3.6.3-14 RI Rev 14 (Draft 2), 01/31/02 North Anna Units 1 and 2 B 3.6.3-11

Containment Isolation ýVae&lvemsp (As]ric.,

ýuansp~eric Ice.(o'~

r c

ua_

(Atnos c.c.

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.6.3.O SR 3,6.3.(

SR Perform leakage rate testing for rnntainrnn nm "ma v*Ivac with resilient seals.

Ia4 O ft VO( oP M

~

4 a5

~

AL~

e~ re Verify each automatic containment isolation valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

3.6.3.OPI

)

FREQUENCY E181 months Cycle each weight or spring loaded check 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.

(JO SR 3.6.3.10 Verify each [I inch containment purge

[18] months valve is blocke 4 restrict the valve from opening > [50Jt.

(continued)

Rev 1. 04/07/95 4.c.3. L.J WOG STS 3.6-14 18 months

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.

4. Not used.

W

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 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 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 also consistent with the current licensing basis.

7. ISTS 3.6.3 ACTION E is not adopted. The Reviewer's Note to TSTF-205, Rev. 5, states £1.r that either ACTION D or ACTION E is applicable. ACTION D is applicable to the 3o6.3-2 North Anna design, therefore, ACTION E i's not adopted. Subsequent requirements are I I, numbered and lettered accordingly.

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

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.

Revision 14 North Anna Units 1 and 2 Page I

Containment Iso~lation Valve (Atmo'P Iric.

.uba moSp

i1c, ce-on ~isert7-nd Dual')

B3.6.3 BASES SURVEILLANCE

-SR 3.6.3.-*)

REQUIREMENTS (continued)

For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of l.0CFR 50. Appe*djxjj "is required to ensure OPERABILITY.

Operating experience has demonstrated that this type of seal has the potential to dporade in a shorter

.iot d

o han.

doohrsa tps*_.-/Based on this obs~ervation4rd-dh*e dirctpl*tinngthis penetration le tight (due tmornc and treai on the diet th between containment rn tnvronet) laFrequ~en/cy It84 days was established as pnat of the NC C) i

~Leakage De) resolutionf Generic Issue B-20, "Contai n ekg u to Seal eioration' (Ref. 3).

(ddi -

a

I-)

his SR u

p e

rformed ft-h i.03-da yz aft~er n

va euency was cnosen "ain t cyc ig the valve could introduce additional seal

~deg~radation (beyond ýthat fc n

toa that has not been o ned.

us.

tecrea'ng te r*ntervT-I~iiml ays) is a prudent meas~p'after a valve

,has been o.pene...

T5TF -wr rs F*,*fq-."'7; Automatic contairnment isolation valves close on a 5

"~

I containment isolation signal to prevent leakage of P11 radioactive material from containment following a DBA.

This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. This surveillance is not required for hva yes that are ocked. sealed. or otherwise secured in the L4ai7ect 4red sition under administrative controls.

The S/ (I9S monthFrequency is based on the need to perform this 13L)

urveillance under the conditions that apply during a 4i 0

"I outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown that these components usually pass this Surveillance when performed at the-lB)'IBmonth Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliabilit stand int.

,C k

"(continued)

Rev 1. 04/07/95

©0 3.b3-Z

'3. L.1 -if 3.4 1 -5ý

k.,

WOG STS SR 3-6-34 iptry,-,.

B 3.6-42

JUSTIFICATION FOR DEVIATIONS ITS 3.6.3 BASES, CONTAINMENT ISOLATION VALVES

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

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

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

5. Typographical/grammatical error corrected.

6. The sentence in the ACTIONS C.1 and C.2 Bases, "A check valve may not be used to 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 section 6.4.2.1, is added to the References. UFSAR section 6.4.2.1 specifies four containment penetrations which use check valves outside of containment in conjunction 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 are classified as active components for the purposes of functional specification, inservice inspection, testing, and valve design (re: Regulatory Guide 1.146). Check valves are classified as passive components for the purposes of single failure and system design."

The reference in the ISTS 3.6.3 Bases that is deleted is part of a discussion that addresses failures of automatic valves for the purposes of single failure. This is not accurate for 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 containment isolation signal. North Anna is allowed to utilize some check valves as t? iq containment isolation valves. These check valves are considered automatic containment isolation valves for the purpose functional specification, inservice inspection, testing and valves design. However, check valves serving as containment isolation valves do not receive a containment isolation signal. Therefore, this Surveillance cannot be performed 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 NRC RAI: CTS 3.6.2.2 ACTION a requires that after HOT STANDBY (MODE 3) is reached, the action is to "restore the inoperable subsystem to OPERABLE status within 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 next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." CTS 3.6.2.2 ACTIONS b and c have been modified in the CTS markup by a similar statement. This modification is Insert 2 and justified by DOC L.2. The corresponding ITS ACTION is ITS 3.6.7 Required Action E.2, which requires the plant to be in MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months .

Even though the overall time to complete the CTS and ITS ACTIONS of 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months does 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 is a change in converting the CTS to the ITS. This change relates to when the commencement of shutting down to MODE 5 begins or is declared. In the CTS it officially starts immediately after the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowed outage time to restore the subsystem to OPERABLE status is completed.

In the ITS it beings immediately after MODE 3 is reached. This change is not indicated or justified in the CTS markup for CTS 3.6.2.2 ACTION a, and Insert 2 is incorrect for CTS 3.6.2.2 ACTIONS b and c. The change associated with CTS 3.6.2.2 ACTION a is a More Restrictive change (Time for commencement of shutdown to MODE 5 declared earlier in ITS versus CTS). The change associated with CTS 3.6.2.2 ACTIONS b and c is still Less (L) Restrictive, but Insert 2 should be deleted, and the 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months changed to 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months , with the appropriate justification. Comment: Revise the CTS markup and provide the appropriate discussions and justifications for these More Restrictive and Less Restrictive (L) changes.

Response: The Company will take the action proposed in the Comment, with certain modifications. ITS 3.6.7 CTS Insert 2 is deleted, the CTS markup is modified, DOC L.2 is modified, and DOC M.1 is added to explain the change to the CTS. The time for declaring commencement of Action to place the unit in MODE 5 is changed from up to 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months after entering ACTIONS b and c to immediately.

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

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

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

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 NRC RAI: The last sentence in STS B3.6.6E Bases - E.1 states the following: '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." The ITS markup of ITS B3.6.7 Bases - D.1 deletes this sentence and replaces it with sentences on casing cooling tank and RS pump OPERABILITY. These new sentences do not provide a justification for the 72-hour Completion Time as does the STS statement. Comment: Revise the ITS markup to either retain the STS wording or provide plant-specific wording justifying the 72-hour Completion Time for ITS 3.6.7 Required Action D.1 and provide the appropriate discussions and justifications as necessary.

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

Additional Response: The previous response is superceded. The STS wording in the Required Action D.1 Bases is not consistent with the North Anna design. The originally proposed wording describing the relationship between casing cooling tank inoperability and RS subsystem inoperability is restored. The STS Bases wording describing the 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 ACTIONS D.1 (continued) 3.6.7-4 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 If the inoperable RS subsystem(s) or the casing cooling tank 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 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 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 With an inoperable inside RS subsystem in one train, and an 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 than 100% of required RS flow is available. Therefore, in all 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)

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

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.

kJ 1 ýOn1-k cLv oerwA l,t r' e

c~-'De-Outlr S

' "oL (continued)

WOG STS B 3.6-105 Rev 1. 04/07/95 I 4A'tw" Iar, d 6 4 K 1 0'%

-4

,,j Ppr4 L g

~

ý c-i-.

j-tA4

!n

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

The inside RS subsystem pump NPSH is increased by reducing R14 the temperature of the water at the pump suction. Flow is diverted from the QS system to the suction of the inside RS 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 spray headers and into the containment atmosphere. Heat is transferred from the containment sump water to service water in the spray coolers.

The Chemical Addition System supplies a sodium hydroxide (NaOH) solution to the RWST water supplied to the suction of 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 (pumped from the sump) enhances the ability of the spray to 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.

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

Rev 14 (Draft 1),

01/10/02 North Anna Units 1 and 2 B 3.6.7-2

RS System at B B 3.6 CO AINMENT SYSTEMS B 3.6.. )Recirculation Spray (RS)

System (i ph c)

BASES BACKGROUND to,,ýa JAoe 5ýro T h or ff'oooiA-sr,'

P,6

A +ke

+O1r A-&0AnQ,.(

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 analysis bases.

Each train includes one RS subsystem outside containment and 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 are designed to increase the net positive suction head (NPSH) available to the out *de RS pumps by injecting cold water into the suction of t spray pumps.

The casin coolingwC~7w*_

tank 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 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.

T4 Y4 (e,ý- J iv AM.I.

i Rev 1. 04/07/95 (vi 4, -ý ff B 3.6-100 0

0Z'

H Fe(c,V. 1q t

I I

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

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

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

Definitions 1.1 i.1 Definitions PHYSICS TESTS (continued)

QUADRANT POWER TILT RATIO (QPTR)

RATED THERMAL POWER (RTP)

REACTOR TRIP SYSTEM (RTS)

RESPONSE TIME SHUTDOWN MARGIN (SDM)

b. Authorized under the provisions of 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Regulatory Commission.

QPTR shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 2893 MWt.

The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

SDM shall be the instantaneous amount of reactivity by which the reactor is.subcritical or would be subcritical from its present condition assuming:

a. All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to 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 R13

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

1 11 _

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

Definitions 1.1 11 Definitions SHUTDOWN MARGIN (SDM)

(continued)

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single.RCCA of /l/13 highest reactivity worth, which is assumed to f1JŽ,'

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 temperatures are changed to theEfiominal zero power design levelJ-S A SLAVE RELAY TEST shall consist of energizing

ý and verifying the OPERABILITY of 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 OPERATIONAL TEST actuatin device and verifying the OPERABILITY of (TADOT) ment aas 2

cti e TADOT s all include adjustment. as necessary, of the trip actuating device so that it actuates at the required setpoint within the

(*e*.*'*

~accuracy".*'-

A ll

d

~

~tiI deAL'-',

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

e dexOr WOG STS 1.1-6 Rev 1. 04/07/95 kt, 13 6 IM T-5rf

JUSTIFICATION FOR DEVIATIONS CHAPTER 1.0, USE AND APPLICATION

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

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

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

North Anna Units 1 and 2 Revision 13 I?13 I

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

INSERT 2 The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

INSERT 3 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 moderator temperatures are changed to the nominal zero power design level.

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

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

INSERT 2 The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

INSERT 3 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 moderator temperatures are changed to the nominal zero power design level.

North Anna Units 1 and 2 Page 8 of 1I Revision 13 i103

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

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

L.4 The CTS Section 1.0 definitions of ENGINEERED SAFETY FEATURE RESPONSE TIME and REACTOR TRIP SYSTEM RESPONSE TIME require measurement of the response time from the sensor through the actuated equipment.

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

The purpose of response time testing is to ensure that the system response time, from measurement of a parameter to actuation of the appropriate device, is consistent with the assumptions in the safety analyses. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," dated January, 1996, justified the elimination of the pressure sensor response time testing requirements and allows the response time for selected components to be verified instead of measured.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," provides the basis for using allocated signal processing actuation logic response times in the overall verification of the protection system channel response time. This change is acceptable because the cited Topical Reports have demonstrated that modified response time tests will continue to provide assurance that the systems will perform their functions as assumed in the safety analysis. This change is designated as less restrictive because some components which must be response time tested under the CTS will not require response time testing under the ITS.

L.5 Not used.

North Anna Units 1 and 2 Page 13 Revision 13

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

North Anna Units 1 and 2 Page 9 Revision 13

CHAPTER 1.0, USE AND APPLICATION Not Used.

North Anna Units 1 and 2 Page 10 Revision 13 R 13

Specifications Affected:

SR 3.0.3 and SR 3.0.3 Bases Description TSTF-358, Revision 5 was included in Supplement 2 to the North Anna ITS license amendment.

Revision 6 of TSTF-358 was approved by the NRC and the differences between Revision 5 and Revision 6 are incorporated into ITS SR 3.0.3, SR 3.0.3 Bases, the ISTS markup, and 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 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

Surveillances may be performed by any series of sequential, overlapping, or total steps.

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 "11once per.

" basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

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 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.

R2 I R2 R13 If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 SR 3.0.1 SR 3.0.2 SR 3.0.3 3.0-4

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 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 R13 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.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While-up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of R2 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 RII 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 R13 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 impacts, determination of risk management action thresholds, and risk management action up to and 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 (continued)

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

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

.6--

otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance p tr-An4'~'of the Surveillance or between performances of the

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

Failure to

( e"rl/-/"

/perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.p/

J*.-

SR 3.0.2 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.

1*J.

SR 3.0.3 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 A

rI'Sk e*t-I*o-kit, the specified Frequency, whichever is-th-NThis dela-y pe,..

,j Iperiod is permitted to allow performance of t e

,9-ra If the Surveillance is not performed within the delay 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 and the Surveillance is not met, the LCO must immediately be (continued)

WOG STS 3.0-4 Rev 1, 04/07/95 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 impacts, determination of risk management action thresholds, and risk management action up to and 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.

North Anna Units 1 and 2 Insert to PageB 3.0-13 Revision 13 Revision 13 Insert to Page B 3.0-13 North Anna Units I and 2

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 specified surveillance interval with a maximum allowable extension not to exceed 25 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 changes the CTS by adding, "If a Completion Time requires periodic performance on a 'once per...' basis, the above Frequency extension applies to each performance after the initial performance." The remaining changes to CTS 4.0.2 are discussed in 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 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 to 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 Revision 13 Page 22

DISCUSSION OF CHANGES SECTION 3.0, LCO AND SR APPLICABILITY 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. If the 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 and the Action 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 to perform the missed Surveillance, but requires declaring the LCO not met and the ACTIONS be followed if the allowed outage time is greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS SR 3.0.3 permits the delay of declaring the LCO not met (and taking 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 Frequency of the Surveillance, whichever is greater. For example, if the Surveillance 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 Frequency is 30 days, 30 days is allowed. However, a risk evaluation must be performed 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 .

IQ 13 Therefore, the ITS allows additional time to perform a missed Surveillance and does not require the LCO to be declared not met and the ACTIONS to be followed if a Surveillance is not performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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

92.

reasonable assurance that the subject equipment is OPERABLE. It is overly conservative to assume that systems or components are inoperable when a surveillance has not been performed because the vast majority of surveillances do in fact demonstrate that systems or components are OPERABLE. When a surveillance is missed, it is primarily a question of OPERABILITY that has not been verified by the performance of a Surveillance Requirement. As stated in the ITS Bases, "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) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.... All missed Surveillances will be placed in the licensee's Corrective Action Program." Therefore, the missed Surveillance will be performed at the first reasonable opportunity, will be evaluated for the effect on plant risk, and will be investigated under the plant corrective action program. As a result, this less restrictive requirement has no detrimental effect on unit safety.

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

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

Specifications Affected:

CTS 3.3.3.1 Description CTS Table 3.3-6, Action 35, was marked "See ITS 3.3.3." This Action is not dispositioned in ITS 3.3.3 and should have been relocated under DOC R. 1 of CTS 3.3.3.1. The CTS markup for Unit 1 and 2 is revised to delete Action 35 and reference DOC R.1.

The ITS and Bases are unaffected.

671* Z..3. (

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

TABLE NOTATION required by the MiniernChannels OPERABLE requ ~ement,

'/* I ACTION 20 -

With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requie-27 Z p e r o r a r a s r e o

h o i o e r ea u I e -g h7 ment, comply with the ACTION requirements of

),/_

Specification 3.4.6.1.

l oc e

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

With the number ochannels OPERABLE less than required by the Minimum annels OPERABLE requirement, comply with the ACTION requtrennts-of Specification 3.92.

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.

NORTH ANNA -

UNIT 1 3/4 3-37 Amendment No.

64, 121

[DaJ

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

TABLE NOTATION by the Minimum C hnnels OPERABLE requir, fment, perform

\\

if

~area surveys peFthe 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 by the Minimum Channels OPERABLE requirement, comply Jwith the ACTION requi-ents of Specification 3..12.

ACI Wit the:I numberc o anel s

OP

°ERABrLElu:=essth 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 to OPERABLE atus within 7 days f the event, or 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

/GZ-4", /3 4ý'- TS 3, 11. 1 4 0 1ý2.f P I?;,

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected:

ITS 3.4.3 Description North Anna license amendment 226 (Unit 1) and 207 (Unit 2), dated May 2, 2001, revised the Unit 1 and Unit 2 heatup and cooldown curves. The revised curves are incorporated into the 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

2000.00 ---

oooo U)(n 10.0 a.t a._

Unacceptable 0

Operation x

)1000.00 i

I A c c e p t a b le

,)

Heatup Rates (F lh r)

Oa 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 Heatup Rates up to 60 0F/hr, Applicable for the first 32.3 EFPY, 1 R13 Including Margins for Instrumentation Errors Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 3.4.3-3

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 2000.00 I

L _

I

a.

S1500.00 CL

.j Unacceptable 0

Operation

=

-Acceptable SCooldown Rates pe ato (F/hr) 0 500.00 20 a-0 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 Cooldown Rates up to 1000F/hr, Applicable for the first 32.3 EFPY, R13 Including Margins for Instrumentation Errors Rev 13 (Draft 1),

01/08/02 North Anna Units 1 and 2 3.4.3-4

RCS P/T Limits 3.4.3 Material Property Basis Limiting Material: Lower Shell Plate Limiting ART at 34.3 EFPY: 114-T, 218.5 Deg. F 314-T, 195.6 Deg. F 2500.00 1

oo oo

-Limit 2000.00 0

Operation WI-1~

IIT--

1+i 0

J I

50 100.0 150 10 15 30 35 Fiur 3.4.3-3 (pe 1 of

1)

HetpRaeW Acceptable UHnt2R Ratt Operation 500.00-60

-F=-P 11H I_

I II 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, 1R13 Including Margins for Instrumentation Errors Rev 13 (Draft 1),

01/08/02 North Anna Units 1 and 2 3.4.3-5

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 C4l 1500.00 Unacceptable 0i 0

k Ope atio I+

I

) 1000.00 Ix

"*~~

Acceptablbe "6

t _*

Operatio Cooldown Rates Oeaion (Flhr) prto 0

7_

500.00-20 40 60 100 I

I I.

0.00 0

50 100 150 200 250 300 350 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 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 3.4.3-6

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*1500.00 U) a 3

1

_Unacceptable g1 0

Operation "I

G)1000.00 "cU b

Acceptable Ohperr o

Operation S~20 40 I

5)100.00 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 600F/hr, Applicable for the first 32.3 EFPY, Including Margins for Instrumentation Errors Revision 13 North Anna Units 1 and 2 Insert to Page 3.4-6 North Anna Units I and 2 Revision 13 Insert to Page 3.4-6

ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS 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 1500.00 C

0)

Unacceptab,,e_

0_

Operation 7

a-xI d

1 ooo1o a:

- Acceptable 10*Cooldown Rates Operation 00 20 500.00 604 100 gio~o------------------------ -------

0.00 0

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

Figure 3.4.3-2 (page 1 of 1)

Unit 1 RCS Cooldown Limitations Cooldown Rates up to 1 00°F/hr, Applicable for the first 32.3 EFPY, Including Margins for Instrumentation Errors North Anna Units 1 and 2 Insert to Page 3.4-6 Revision 13

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 2000.00 H

P 1-1

-4 1

L3.

u 1500.00 r0 Unacceptable

,,,o Operation

0) 1000.00 Acceptable "Heatup Rates 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 Kevislon 13 North Anna Units 1 and 2 Insert to Page 3.4-6 Insert to Page 3.4-6 North Anna Units I and 2

ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS 2500.00 2000.00

0.

6) to 1500.00 U) 0~

U)

)1000.00 c) 500.00 0.0(

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 Unacceptable Operation

- Acceptable Cooldown Rates Operation (F/hr)

+

0 20

-a 40 60 100 0LifhifAIL 0

50 100 150 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 0F/hr, Applicable for the first 34.3 EFPY, Including Margins for Instrumentation Errors North Anna Units 1 and 2 Insert to Page 3.4-6 Revision 13 350

-A 200 250 300

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:

2500.00 2000.00 S1500.00

4) 0 "1

S1000.00 "4) 500.00 0.00 1/4-T, 218.5 deg. F 3/4-T, 195.6 deg. F 0

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

North Anna Unit 1 Reactor Coolant System Heatup Limitations (Heatup Rates up to 60 F/hr)

Applicable for the first 32.3 EFPY (Including Margins for Instrumentation Errors)

NORTH ANNA - UNIT I 3/4 4-27 Amendment No. 16,74, 117,170,

/,p j3

-899 226

-T.73 -ý, 41,3

32 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 Cn a)

I-S1500.00 Cn IL CM a)

S1000.00 3r n,

500.00 0.00 0

INI I~

50

4-

' z

*3.

r 100 r 1K r1k NE, gk, 72-WON T1111 NOT,:

R WE Pm I &

Z; mi

'g

-I 150 200 Wide Range Cold Leg Temperature (Deg. F)

North Anna Unit 1 Reactor Coolant System Cooldown Limitations (Cooldown Rates up to 100 F/hr)

Applicable for the first 32.3 EFPY (Including Margins for Instrumentation Errors)

NORTH ANNA - UNIT 1 3/4 4-28

/O6Z a 3ý f 3 Amendment No. 16,74,117,

170, 41V 1' 4-89, 226 4e Figure 3.4-3 North Anna Unit 1 Reactor Coolant System Cooldown Limitations 05-02-01

24 250 300 350

-pe P91f

'14 -"N

3 --3 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 En Ur) o)

I.

""1500.00 U) cm

0) 0,1 "I

a) 1000.00 C,

500.00 0.00 0

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

North Anna Unit 2 Reactor Coolant System Heatup Limitations (Heatup Rates up to 60 F/hr)

Applicable for the first 34.3 EFPY (Including Margins for Instrumentation Errors)

NORTH ANNA - UNIT 2 3/4 4-27 o2 Amendment No. 600-41, I f*-O y'4},.%

207 350 Figure 3.4-2

ý7-/ý J, 'f, -3

-/7>

2500.00 2000.00 2M S1500.00

(.

0 _1 0 "t 01000.00

"(V 500.00 0.00 0

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

North Anna Unit 2 Reactor Coolant System Cooldown Limitations (Cooldown Rates up to 100 F/hr)

Applicable for the first 34.3 EFPY (Including Margins for Instrumentation Errors)

NORTH ANNA - UNIT 2 3/44-28

,Oc 3

"f Amendment No. 619,-49,r14,

. l3 207 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

Specifications Affected:

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

RCS P/T Limits 3.4.3 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.3 RCS Pressure and Temperature (P/T) Limits LCO

3.4.3 APPLICABILITY

RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained within the limits specified in Figures 3.4.3-1 and 3.4.3-2 (Unit 1) and Figures 3.4.3-3 and 3.4.3-4 (Unit 2) with:

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

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

c. A maximum temperature change of 10OF in any one hour period during inservice hydrostatic and leak testing operations above the heatup and cooldown limit curves.

At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 30 mnue A.

NOTE --------

Required Action A.2 shall be completed whenever this Condition is entered.

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

B.

Required Action and associated Completion A.1 Restore parameter(s) to within limits.

AND A.2 Determine RCS is acceptable for continued operation.

B.1 Be in MODE 3.

AMn 30 minutes 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 6 hours Time OT Conaition A r,,__

not met.

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.

Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 t R13 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3.4.3-1

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 one RHR loop shall be in operation.

and

-NOTES

1. All RHR pumps may be removed from operation for

15 minutes when switching from one loop to another provided:

a. The core outlet temperature is maintained > 10'F below 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.

One required RHR loop inoperable.

A.1 Initiate action to Immediately restore RHR loop to OPERABLE status.

Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 R13 RAI 3.9.5.-1 R4 R13 3.4.8-1

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 operators, and one of the following pressure relief 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 leg temperature 52350F (Unit 1), 270°F (Unit 2); and

2.

395 psig (Unit 1), 375 psig (Unit 2) when any RCS cold 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.

APPLICABILITY:

ArTTnMhK MODE 4 when any RCS cold leg temperature is 270°F (Unit 2),

MODE 5, MODE 6 when the reactor vessel head is on.

2350F (Unit 1),

CONDITION REQUIRED ACTION I

i A.

Two LHSI pumps capable of injecting into the RCS.

A.1 Initiate action to verify a maximum of one LHSI pump is capable of injecting into the RCS.

COMPLETION TIME Immediately I ________________________

-p ______________

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

~RAI I3.4-12 RI R13 R13 I

IIU 3.4.12-1

RCS Isolated Loop Startup 3.4.18 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.18 RCS Isolated Loop Startup LCO 3.4.18 Each RCS isolated loop shall remain isolated with both loop isolation valves closed and power removed from the valve operators unless:

a. The isolated loop is filled and:

1. The boron concentration of the isolated loop is ' the boron concentration required to meet SDM of LCO 3.1.1 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 recirculation line flow of Ž 125 gpm for Ž 90 minutes prior to opening the cold leg isolation valve; and

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:

NOTE -----

Seal injection may be initiated to the RCP in the isolated, drained loop and continued during filling of the 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.

1. Pressurizer water level is maintained Ž 32% prior to and during the opening of the hot or cold leg isolation valves; and

2.

The hot and cold leg isolation valves are fully open within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after the loop is filled.

Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 3.4.18-1

ITS 3.4.3, RCS PRESSURE AND TEMPERATURE (P/T) LIMITS INSERT Figures 3.4.3-1 and 3.4.3-2 (Unit 1) and Figures 3.4.3-3 and 3.4.3-4 (Unit 2) with:

a.

A maximum heatup of 60OF in any one hour period;

b.

A maximum cooldown of 1 00°F in any one hour period; and I *

c.

A maximum temperature change of 10°F in any one hour period during inservice hydrostatic and leak testing operations above the heatup and cooldown limit curves.

North Anna Units 1 and 2 Insert to Page 3.4-5 Revision 13

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 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

...............................,- NOTES...........................

reieio f

i. Al1 RHR pumps may bee-er i for 5 15 minutes when Sswitching from one loop o anot r provided:

a.

(the core outlet temperature is maintained > 10F low saturation temperaturea

.rations rpe ermitted/that would datse ion 7 4he RCS boran concentrat.idn' : Vd

'j,

/es~

s-2 L~O3,1.)a, 7R14D

/Ply T~s r-

c.

No draining operations to further reduce the RCS water volume are permitted.

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.

APPLICABILITY:

MODE 5 with RCS loops not filled.

ArTTAW*

LCUNDIUIION REQUIRED ACTION COMPLETION TIME A. One RHR loo inoperable.

A. I Initiate action to restore RHR loop to OPERABLE status.

Immediately

-S7-/-TF-) 63 (continued)

Rev 1. 04/07/95 S13 CA5 LCO 3.4.8 I

I WOG STS 3.4-17

LTOP System 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP)

System LCO

,co 3.9'3 APPLICABILITY:

[2 wo residual at removal (RH suction relie valves witysetpoints > [43, 1 psig and

[463.

psig. or]

(

[3.

One --

RV with a li ft etting within limits T7; -i--28, 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-"

b.

The RCS depressurized and an RCS vent of -_-.0 square inches.

-*s -*74

-,3 MODE 4 when a RCS cold leg temperature is 5 2

MODE 5, MODE 56 when_thýe cjtor vesel head is on.

oisolation sonl re uired when accumulator prres S greater than or equa t, maxiip re~ss o

exis ng RCS cof le terne ue&roe b

1uthe P~i m it cu #s proi-in, t6eIi..

]/

P e--

2.

6L/a

z.

7l,i,2),

-'42) waher

/ 30 OFf-iU1r42-)

3.4-27 Rev 1. 04/07/95 TRAI 4 / 9 1a.13 L.6c 3.53 AfgIdc4 t 3

I.

WOG STS

ITS 3.4.18, RCS ISOLATED LOOP STARTUP INSERT 1 LCO 3.4.18 S75* 3. ý" t,5*

q', 1, 6 3,

j L(.0 L(-o

?. 61 ' 'hsq Each RCS isolated loop shall remain isolated with both loop isolation valves closed and power removed from the isolation valve operators unless:

a.

The isolated loop is filled and:

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 opening the hot leg isolation valve; ap4d.Y

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

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:

3, cL(

.4, 2 O

Z 2.

N O T E S ---------------------------------------

Seal injection may be initiated to the RCP in the isolated, drained loop and continued during filling of the 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.

1.

Pressurizer water level is maintained > 32% prior to and during the opening of the hot or cold leg isolation valves; and

2.

The hot and cold leg isolation valves are fully open 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.

North Anna Units 1 and 2 Insert to Page 3.4-49 Revision 13 I d '3 Le,.D 2).. W I,t.-0'

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 3.4.6.3, 3.4.7.3, and 3.4.8.2 require verification of correct breaker alignment and indicated power 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.

RFACTOR COOLANT SYSTEM SHUTDOWNN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The quired RHR ubsystems sh be demons mied OPERABIE per

___/_

4 4 / D 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.

yCArL S?

R Lf. ý 2

',p 3, q,6.

4.4.1.3.3 The required steam generator(s) shall be determined OPERABLE by verifying 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 .

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

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

>n r4 0

aFor the A

<.I hours. circ R

nreactor cootdiita NORTH ANNA - UNIT 1 3/4 4-3a Amendment No. -2 137 1c-c 2 i2

/

A.b 8-27-90 Z-A 2 S'URVEIILLANCE REQUIREMENTS Lk. L10 I

REACTOR COOLANT SYSTEM URVMAN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The requ RHR subs shall be onstrated OP Spe&

tion 4.7.9.1,1

0.

4.4.1.3.2 The required i

rec ol pum s,

not in-operauion, sh determined to be OPERABLE once per 7 days by verify.ng correct breaker alignment and indicated power availability.

The required steam generator(s) shall be determined OPERABLE by verifying 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 .

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.

or

b.

Verifying at least one RHR Loop is in operatio aid. "

nt.....

S1.

ifIe'RCS temperaturo,7 140F th ýme since entry -rt6 MODE 3 is

< 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.

or MOD/

i

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*....................................

Amendment No. 120 NORTH ANNA - UNIT 2 04/

z-s

8-27-90 S4.4.1.3.3 u b

4.4.1.3.4 1(0;3 I

3/4 4-3a

DISCUSSION OF CHANGES ITS 3.4.6, RCS LOOPS - MODE 4 perform the cooldown. Requiring immediate actions to avoid boron stratification and to restore a loop to OPERABLE status are appropriate. This change is designated as more restrictive because is requires immediate action stop RCS boron concentration reductions 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 a cooldown.

M.2 CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE and at least one must be in operation. This requirement is modified by a note that states that all reactor coolant pumps and residual heat removal pumps may not be in operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

ITS 3.4.6 contains the same allowance, but limits the use of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

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 certain infrequent startup tests which require coolant flow to be stopped. This change is acceptable because it ensures that boron stratification or inadequate decay heat removal do not occur should 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 is designated as 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 period when that restriction does not currently exist.

M.3 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be determined OPERABLE by verifying correct breaker alignment and indicated power availability. ITS SR 3.4.6.3 requires verification that correct breaker alignment and indicated power are available to the required pump not in operation. LCO 3.4.6 allows a combination of reactor coolant pumps and RHR pumps. This changes the CTS by requiring verification of correct breaker alignment and indicated power availability on required RHR pumps which are not in operation.

The purpose of the CTS is to ensure a standby pump is available to provide RCS cooling should the operating pump fail. This change is acceptable because the verification of proper breaker alignment and power availability ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. This change is designated as more restrictive because it requires performance of the Surveillance on RHR pumps in addition to reactor coolant pumps.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.4.1.3 states that two coolant loops consisting of any combination of RCS loops and RHR loops shall be OPERABLE and contains a description of what constitutes an OPERABLE Reactor Coolant loop and Residual Heat Removal loop. ITS 3.4.5 North Anna Units 1 and 2 Page 2 Revision 13

wis

I?-3 q

? -7,3 The requiredf aRE c

coolp-rj OPERABLE once per 7 days power availability.

54' >i.Th2 e

The required steam generator(s) shall be determined OPERABLE by verifying 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 "a.

exifyxg at leasx-4 e Reactor-°Co t Pump is in ope/ra**on-J 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 operation*o NORTH ANNA - UNIT I 3/4 4-3a 7

/

Amendment No. -2 137 X44P

-t TJSt A.1 8-27-90

"(7T

.SI4 3,'.

(-LI I

0

REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS

A~L1, 73

-e A, qZ

/i-..,*,.(

,'L tot in opercion, shall be determined to be 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 41 31A'o 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 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 aC e b

Verfyig t I 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 Q2cr.e I

//

Amendment No. 120 Ir3 D/4/

-r_ C-5 8-27-90 I

)

DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED M.2 CTS 3.4.1.3, Action a, states that when less than the two required coolant loops are OPERABLE, immediate action must be taken to return the required loops to OPERABLE status as soon as possible and the unit must be in cold shutdown within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . CTS 3.4.1.3, Action b, states that when no coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required coolant loop to operation. 'ITS 3.4.7, Action A applies when one required RHR loop is inoperable and one RHR loop is OPERABLE or when the required steam generator secondary side water level is not within limits and one RHR loop is OPERABLE and requires immediate action to restore the RHR or steam generator. ITS 3.4.7, Action B states that when the required SG secondary side water level is not within limit and one RHR loop is OPERABLE, action must be taken to restore a second RHR loop to OPERABLE status or to restore the SG secondary side water level within limit immediately. ITS 3.4.7, Action C, states that if no required RHR R13 loops are OPERABLE or if the required RHR loop is not in operation, suspend all operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1 and action must be immediately initiated to restore one RHR loop to OPERABLE status and operation. This changes the CTS by revising the actions to be taken if both RHR loops are inoperable. The change in the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1 is described in DOC L.4.

This change is acceptable because it provides appropriate actions for a loss of one or more required RHR loops or SG. If both required RHR loops are inoperable, suspending lei'?

all operations involving a reduction of RCS boron concentration is appropriate because all forced flow used to ensure proper mixing of RCS boron is lost. This change is designated as more restrictive because it adds an additional action to the CTS.

M.3 CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE and at least one must be in operation. This requirement is modified by a note that states that all reactor coolant pumps and residual heat removal pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

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 the use of the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

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 certain infrequent startup tests which require coolant flow to be stopped. This change is acceptable because it ensures that boron stratification or inadequate decay heat removal do not occur should 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 is designated as 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 period when that restriction does not currently exist.

M.4 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be determined OPERABLE by verifying correct breaker alignment and indicated power g 1 availability. ITS SR 3.4.7.3 requires verification that correct breaker alignment and indicated power are available to the required RHR pump not in operation. This changes North Anna Units 1 and 2 Page 3 Revision 13

DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED the CTS by requiring verification of correct breaker alignment and indicated power availability on required RHR pumps which are not in operation.

The purpose of the CTS is to ensure a standby pump is available to provide RCS cooling P 13 should the operating pump fail. This change is acceptable because the verification of proper breaker alignment and power availability ensures that an additional RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. This change is designated as more restrictive because it requires performance of the Surveillance on RHR pumps in addition to reactor coolant pumps.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA. 1 (Type 3 - Removing Procedural Details for Meeting TS) CTS Surveillance 4.4.1.3.4 states that at least one Reactor Coolant pump or RUR loop shall be verified to be in 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 . ITS SR 3.4.7.1 states 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 . This changes the CTS by moving the requirement to verify that the RHR loop is circulating reactor coolant to the Bases. Other related changes are described in LA.3 and L.1.

The removal of this detail for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be in the Technical Specifications in order to provide adequate protection of the public health and safety. The ITS retains the requirement that a reactor coolant loop be in operation, and a loop that is in operation will be circulating reactor coolant. As described in the ITS Bases, verification that a reactor coolant loop is in operation includes flow rate, temperature, or pump status monitoring. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed form the Technical Specifications.

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements) CTS Surveillance 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 that one RIR loop is in operation. It goes on to provide minimum RHR flow rates dependent on RCS temperature or time since entry into MODE 3. ITS Surveillance 3.4.7.1 requires 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 . This changes the CTS by moving the RHR minimum flow requirements to the Technical Requirements Manual.

The removal of these details for performing surveillance requirements from the Technical Specifications is acceptable because this type of information is not necessary to be North Anna Units 1 and 2 Page 4 Revision 13

REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS AJ 8-2TS 8-27-90 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 (A D2 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.

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.

c@)

NORTH ANNA - UNIT 1 3/4 4-3a

2 ?cz7e

/

j Amendment No. ;Q; 137

/?a/1?

I

8-27-90 REACTOR COOLANT SYSTEM L}. Z

>'K 3'i

4.4.1.3.2 The requiredt2E fc.ý2t)pump(s),

if not in operation, shail be aetermmnco to oe OPERABLE once per 7 days by verifying correct breaker alignment and indicated power availability.

(2rI S 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, Xr2 1

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 "

f actoror by:

a. 1of* es on

-'co

, u*¢*

4lD (A2

b.

Verifying at least one RHR Loop is in opei

1.

if theoRC§temperature ator40 0 co

< 1 O0'ours. circulatin imactor coc NORTH ANNA - UNIT 2 3/4 4-3a Amendment No. 120 aye2 of.2-~~

13 (D

I I

DISCUSSION OF CHANGES ITS 3.4.8, RCS LOOPS - MODE 5, LOOPS NOT FILLED RCS boron concentration is appropriate because all forced flow used to ensure proper mixing of RCS boron is lost. This change is designated as more restrictive because it adds an additional action to the CTS.

M.2 CTS 3.4.1.3 contains an allowance for all reactor coolant pumps or RHR pumps to be de energized for up to one hour. ITS 3.4.8 allows all RHR pumps to be removed from

[ t~"

operation for<* 15 minutes for switching from one loop to the other only and also requires that no draining operations to further reduce the RCS water volume are permitted.

This change is acceptable because the Note provides sufficient time to perform loop switching operations and provide adequate controls. The startup tests performed using the CTS Note allowance in MODE 4 or 5 with loops filled are not performed with the 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 those tests are not needed in this condition. Stopping all operating RIiR loops when the RCS is not filled should be limited to short periods of time because of the reduced inventory of water available to absorb decay heat. Stopping all RHR pumps during loop swapping operations is necessary to ensure that pump vortexing does not occur if both pumps are run simultaneously. Fifteen minutes is sufficient time to perform the loop swapping operation without excessive increases in RCS average temperature due to lack of decay heat removal. Adding the additional condition that no draining operations be performed when the pumps are stopped is reasonable given the low RCS water level and the unavailability of the RHR pumps to add inventory to the RCS if needed.

M.3 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be determined OPERABLE by verifying correct breaker alignment and indicated power availability. ITS SR 3.4.8.3 requires verification that correct breaker alignment and indicated power are available to the required RHR pump not in operation. This changes the CTS by requiring verification of correct breaker alignment and indicated power availability on required RHR pumps which are not in operation.

The purpose of the CTS is to ensure a standby pump is available to provide RCS cooling should the operating pump fail. This change is acceptable because the verification of proper breaker alignment and power availability ensures that an additional RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. This change is designated as more restrictive because it requires performance of the Surveillance on RIR pumps in addition to reactor coolant pumps.

RELOCATED SPECIFICATIONS None North Anna Units 1 and 2 Page 3 Revision 13

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected:

ITS 3.4.7 and ITS 3.4.7 Bases Description ITS LCO 3.4.7 requires two RHR loops be OPERABLE or one RUR loop be OPERABLE with the secondary side water level of one Steam Generator (SG) > 17%. Condition B states "One or more required SGs" and Required Actions A.2 and B.2 require action to restore required SGs.

The reference to more than one required SG in Condition B and Required Actions A.2 and B.2 is inconsistent with the LCO. Condition B and Required Actions A.2 and B.2 are revised to refer to a single required SG. The ACTION Bases are also revised. This change affects ITS 3.4.7, the ITS 3.4.7 Bases, the ISTS markup, and the ISTS Bases markup. DOC M.2 is revised to reflect 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.

B.

Required SG with secondary side water level not within limits.

AND One RHR loop OPERABLE.

C.

No required RHR loops OPERABLE.

OR Required RHR loop not in operation.

OR A.2 Initiate action to restore required SG secondary side water level to within limits.

B.1 Initiate action to restore a second RHR loop to OPERABLE status.

OR B.2 Initiate action to restore required SG secondary side water level to within limits.

C.1 Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1.

AND Immediately Immediately Immediately RAI 3.4-22 R 1 R13 R1RAI 3.4-22 R13 RAI 3.4-22 RAI 3.4-22 Ri R13 Immediately R1 C.2 Initiate action to Immediately restore one RHR loop to OPERABLE status and operation.

Rev 13 (Draft 2), 01/25/02 North Anna Units 1 and 2 3.4.7-2

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 circulation for these purposes. However, one additional RHR loop is required to be OPERABLE, or the secondary side water level of at least one SG is required to be ' 17% with the associated loop isolation valves open.

Operation in other MODES is covered by:

LCO LCO LCO LCO LCO 3.4.4, 3.4.5, 3.4.6, 3.4.8, 3.9.5, LCO 3.9.6, "RCS Loops-MODES 1 and 2";

"RCS Loops-MODE 3";

"RCS Loops-MODE 4";

"RCS Loops-MODE 5, Loops Not Filled";

"Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and "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.

A.1, A.2, B.1, and B.2 If one RHR loop is OPERABLE and the required SG has secondary lR11 side water level < 17%, redundancy for heat removal is lost.

Action must be initiated immediately to restore a second RHR loop to OPERABLE status or to restore the required SG secondary side water level. Either Required Action will restore redundant heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

C.1 and C.2 If a required RHR loop is not in operation, except during I3422 conditions permitted by Note 1 and Note 4, or if no required RI RHR loop is OPERABLE, all operations involving introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RHR loop to OPERABLE status and operation must be initiated. Suspending the introduction of coolant into the RCS of coolant with boron concentration less than required to meet the minimum SDM of (continued)

Rev 13 (Draft 2), 01/25/02 North Anna Units 1 and 2 ACTIONS B 3.4.7-4

ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED INSERT A.

One required RHR loop inoperable.

AND One RHR loop OPERABLE.

B.

(0ýmoreyequired with secondary side water level not within limits.

AND One RHR loop OPERABLE.

A.1 Initiate action to restore a second RHR loop to OPERABLE'status.

OR A.2 Initiate action to restore required SGjsecondary side water level to within limits.

Initiate action to restore a second RHR loop to OPERABLE status.

B.1 OR B.2 Initiate action to restore required SC-secondary side water level to within limits.

Immediately Immediately Immediately

1)

Iea3 Immediately North Anna Units I and 2 Insert to Page 3.4-15 Revision 13 03 0Iea I

I-

1f RCS Loops-MODE 5. Loops Filled B 3.4.7 BASES APPLICABILITY or the secondary side water level of at least*gIjSG&is 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";

irn 'a A r, "Orr, I 'nnns-MODl 3"!

LCO 3.4.6, LCO 3.4.".

LCO 3.9.5.

LCO 3.9.6, "RCS Loops-MODE 4":

"RCS Loops-MODE 5, Loops Not Filled":

"Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6): and "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

0 (V

A.1(

AA 0 If one RHR loop is'6Ian~

Vthe required SG(i.&

secondary side water levelV <

L17*, redundancy for heat removal is lost.

Action must be initiated immediately to 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.

If QNHR 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 he i

n t

teimii~portance o maintainini B 3.4-35 (continued)

Rev 1. 04/07/95

..1 ACe TO ACTIONS WOG STS

,13 rlý

DISCUSSION OF CHANGES ITS 3.4.7, RCS LOOPS - MODE 5, LOOPS FILLED M.2 CTS 3.4.1.3, Action a, states that when less than the two required coolant loops are OPERABLE, immediate action must be taken to return the required loops to OPERABLE status as soon as possible and the unit must be in cold shutdown within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . CTS 3.4.1.3, Action b, states that when no coolant loops are in operation, all operations involving a reduction in boron concentration of the RCS must be suspended and action must be initiated to return the required coolant loop to operation. ITS 3.4.7, Action A applies when one required RHR loop is inoperable and one RHR loop is OPERABLE or when the required steam generator secondary side water level is not within limits and one RHR loop is OPERABLE and requires immediate action to restore the RHR or steam generator. ITS 3.4.7, Action B states that when the required SG secondary side water level is not within limit and one RHR loop is OPERABLE, action must be taken to restore a second RIR loop to OPERABLE status or to restore the SG secondary side water level within limit immediately. ITS 3.4.7, Action C, states that if no required RHR R13 loops are OPERABLE or if the required RIR loop is not in operation, suspend all operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1 and action must be immediately initiated to restore one RIR loop to OPERABLE status and operation. This changes the CTS by revising the actions to be taken if both RIR loops are inoperable. The change in the action from suspending reductions in boron concentration to suspending introduction of coolant with a boron concentration less than required to meet LCO 3.1.1 is described in DOC L.4.

This change is acceptable because it provides appropriate actions for a loss of one or more required RHR loops or SG. If both required RIR loops are inoperable, suspending [*el' all operations involving a reduction of RCS boron concentration is appropriate because all forced flow used to ensure proper mixing of RCS boron is lost. This change is designated as more restrictive because it adds an additional action to the CTS.

M.3 CTS 3.4.1.3 states that at least two coolant loops shall be OPERABLE and at least one must be in operation. This requirement is modified by a note that states that all reactor coolant pumps and residual heat removal pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

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 the use of the I hour exception to once per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

The purpose of the I hour allowance is to allow the performance of certain infrequent startup tests which require coolant flow to be stopped. This change is acceptable because it ensures that boron stratification or inadequate decay heat removal do not occur should 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 is designated as 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 period when that restriction does not currently exist.

M.4 CTS 4.4.1.3.2 states that the required reactor coolant pump(s), if not in operation, shall be determined OPERABLE by verifying correct breaker alignment and indicated power RI/

availability. ITS SR 3.4.7.3 requires verification that correct breaker alignment and indicated power are available to the required RIR pump not in operation. This changes North Anna Units I and 2 Page 3 Revision 13

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected:

ITS 3.4.11 CTS markup Description CTS Surveillances 4.4.3.2.la and 4.4.3.2.1.b.3 were marked as "See ITS 3.3.1." These Surveillances were not addressed in ITS 3.3.1. The CTS markups for Unit 1 and 2 are revised to remove these Surveillances and DOC L.3 is revised to address the change.

CTS Surveillance 4.4.3.2.2 does not require operating the block valve through one complete cycle of full travel when the block valve is closed to meet the requirements of ACTION A.4 and A.5. ITS 3.4.11 does not require operating the block valve through one complete cycle of full travel (SR 3.4.11.2) when the block valve is closed to meet any Required Action. This change was not addressed. The CTS markups for Unit 1 and 2 are revised to indicate the change and DOC L.4 is added to address this difference between the CTS and the ITS.

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) 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 .

G'-

(A1#

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.-*

SURVEILLANCE REQUIREMENTS c9jrQ 4.4.3.2.1 1

ition t L equire i'etg fSpecifon4..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 accumulators in the PORV control systems through one complete cycle of.

full travel, and IBATON 6 ýfthý flo instrumentation.

c.

At least once per 7 days by verifying that the pressure in the PORV nitrogen accumulators is greater than the surveillance limit.

4.4.3.2.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by operating the valve through one complete c cle of full travel unless the block valve is closed in order to meet h Au nts of ACTIO 3/5n SAecifica mn N.

NORTH ANNA - UNIT 1 3/4 4-7b CýAmendment No. +189, 218 B.

A~CA I I I V4 1.2 P1a 4-I 01011

03-02-99 REACTOR COOLANT SYSTEM SAFETY AND RELIEF VALVES - OPERATING RELIEF VALVES LIMITING CONDITION FOR OPERATION ACTION: (Continued)

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

tr ei 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 eb store maining ino rable lock eTto OPE or 0 at least HOT o

BY "n the 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 valve o

ns r l perati d

y "r~n a C_.

.?..,3

b. At least once per 18 months by:

1. Operating the PORV through one complete cycle of full travel/ýý q,

2. Operating the solenoid gcontrol valves and check valves on the associated accumulators in the PORV control systems through one complete cycle of full travel, and a C NEL CALU

.TIO.Noft

.eactuatl.n.ins.iiiiih46i..

c. At least once per 7 days be verifying that the pressure in the PORV nitrogen Sqi, a I 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 O I'.-..:.:,

I/:r L

el 1)

(Z -':

ý2

DISCUSSION OF CHANGES ITS 3.4.11, PRESSURIZER PORVs L.3 (Category 1 - Relaxation of LCO Requirements) CTS 3.4.3.2, Action A.3, states, "With one or both PORV(s) inoperable due to a malfunction in the PORV automatic control system, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the affected automatic control system(s) to OPERABLE status or place and maintain the affected PORV(s) in manual control.

CTS 4.4.3.2.l.a required performance of a Channel Functional Test every 31 days and CTS 4.4.3.2.1.b.3 requires a Channel Calibration of the actuation instrumentation L13 every 18 months. ITS 3.4.11 does not require the PORV automatic control system for OPERABILITY. This changes the CTS by eliminating the LCO requirement and SRs for the PORV automatic control system.

The purpose of CTS 3.4.3.2 is to ensure the PORVs are available to perform their accident mitigation function. This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. In the applicable MODES for ITS 3.4.11, the PORVs are only credited for manual operator action in the event of a steam generator tube rupture. The PORV automatic control system is not needed to perform this function and, therefore, is not required for PORV OPERABILITY. This change is designated as less restrictive because less stringent LCO requirements and SRs are being applied in the ITS than were applied in the CTS.

L.4 (Category 7-Relaxation of Surveillance Frequency) CTS 4.4.3.2.2 states that each block valve shall be cycled unless the block valve is closed in order to meet the requirements of ACTION A.4 or A.5. ACTIONS A.4 and A.5 require the block valve to be closed for reasons other than excessive PORV seat leakage. ITS SR 3.4.11.2 states that each block valve shall be cycled, but it is modified by a Note stating that the SR is not required to be performed with the block valve closed in accordance with the Required Actions. This changes the CTS by not requiring a cycle of the block valve when the block valve is closed due to excessive PORV seat leakage.

The purpose of CTS 4.4.3.2.2 is to verify the block valve can be cycled if needed.

This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. With the block valve closed in order to isolate a PORV with excessive seat leakage, opening the block valve increases the risk of an unisolable RCS leak as the PORV is already inoperable. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

North Anna Units 1 and 2 Page 5 Revision 13

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected:

ITS 3.4.12 Bases Description The North Anna PORVs are powered by the Instrument Air system during normal operation, with nitrogen accumulators acting as a backup. However, during operation in the LTOP range, the PORVs are only powered by the backup nitrogen accumulators. This design feature was not reflected in the submittal. The ITS 3.4.12 LCO Bases, the Bases for SR 3.4.12.6, the ISTS and ISTS Bases markup, and JFD 8 are revised to reflect this design

LTOP System B 3.4.12 BASES LCO (continued)

APPLICABILITY Note 2 states that accumulator isolation is only required 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 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.

This LCO is applicable in MODE 4 when any RCS cold leg temperature is

2350F (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 that meets the Reference 1 P/T limits above 235 0F (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 overpressure protection during MODES 1, 2, and 3, and MODE 4 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.

R13 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 B 3.4.12-7

LTOP System B 3.4.12 BASES SURVEILLANCE SR 3.4.12.5 REQUIREMENTS (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 to provide the flow path for each required PORV to perform its function when actuated. The valve may be remotely verified open in the main control room.

In addition, the PORV keyswitch must be verified to be in the proper position to provide the appropriated trip setpoints to the PORV actuation logic. This Surveillance is performed if the PORV is used to satisfy the LCO.

The block valve is a remotely controlled, motor operated valve. The power to the valve operator is not required

removed, and the manual operator is not required locked in the inactive position. Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication and alarms, that verify that the PORV block valve remains open and the keyswitch in the proper position.

SR 3.4.12.6 SR 3.4.12.6 requires verification that the pressure in the PORV backup nitrogen system is sufficient to provide motive R13 force for the PORVs to cope with an overpressure event. The Frequency of 7 days is based on operating experience.

SR 3.4.12.7 Performance of a COT is required within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS temperature to

2357F (Unit 1), 270'F (Unit 2) and every 31 days on each required PORV to verify and, as necessary, adjust its lift setpoint. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL OPERATIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The COT will (continued)

Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 B 3.4.12-11

LTOP System B 3.4.12 BASES APPLICABLE RCS Vent Performance (continued)

SAFETY ANALYSES T

LSystem satisfies Criterion 2 of Pthe.NC-7)

LCO This LCO requires that the LTOP System is OPERABLE.

The LTOP System is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE.

Violation of this LCO could lead to the loss of low temperature

!L4gP P J yressure mitigation and violation of the af

-s P0

6 s result of an operational transient.

TS-

_"o OT_

io tniL-lbe cool nt input capability, Ehe LCO requires 4?

."*'~,,-.

nle4 ump and one charging pump able of injectin into the RCS 'and all accumulator discharg a ion va veý-c ose i

A.e hen accumulator pressure r ater re mu ss for the st,

tin RCS dleg tem ue al l owed

n*¢

PTLR./-

sZ:2g ITLRe.

2 TS -F-.2 85-ý The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

jq 6a.

(Tw__ýrlif Two OPERABLE PORVs: or APORV is OPERABLE for LTOP when its block valve*

b Upen, ilts lift tpoint is set to the limito:

Lt'l' power is available to the

)and their control circuits.

l

,ee V

[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)

WOG STS B 3.4-65 Rev 1. 04/07/95

ITS 3.4.12, LTOP SYSTEM INSERT 1 SR 3.4.12.6 SR 3.4.12.6 requires verification that the pressure in the PORV backup nitrogen system is sufficient to provide motive force for the PORVs to cope with an overpressure event. The Frequency of 7 days is based on operating experience.

INSERT 2 A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL OPERATIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

North Anna Units 1 and 2 Insert to Page B 3.4-71 Revision 13

JUSTIFICATION FOR DEVIATIONS ITS 3.4.12, LTOP SYSTEM The ISTS requires the accumulators to be isolated when accumulator pressure is greater than the maximum RCS pressure for the existing cold leg temperature as allowed by the P/T limit curves. The ISTS is revised to require the accumulators to be isolated when accumulator pressure is greater than the PORV lift setpoint pressure given in the LCO.

The North Anna LTOP analysis does not address the situation of an accumulator injecting with the accumulator pressure above the PORV lift setting but below the maximum RCS pressure for the existing cold leg temperature as allowed by the P/T limit curves. The analysis does not address a PORV being used to relieve pressure from accumulator injection. If the accumulator pressure is below the PORV lift setpoint (which is also below the limiting pressure for the existing cold leg temperature), injection of an accumulator cannot exceed the maximum RCS pressure for the existing conditions. This revised allowance is stated in an LCO Note, a Note to Condition C, and a Note to SR 3.4.12.3.

TSTF-285 modified the ISTS Applicability Note to state that the accumulator may be RIK unisolated when accumulator pressure is less than the maximum RCS pressure for the existing cold leg temperature as allowed by the P/T limit curves provided in the PTLR, and moved the Applicability Note to an LCO Note. The movement of the Note to an LCO Note has been adopted in the North Anna ITS. However, the wording changes made to the Note in TSTF-285 are not consistent with the North Anna LTOP analysis, as described in the previous paragraph. Therefore, the Note has been revised to be consistent with the North Anna LTOP analysis.

These more stringent controls on accumulator pressure and accumulator isolation will ensure that the assumptions of the North Anna LTOP design are met.

7. Portions of TSTF-280, Revision 1, are not adopted. The revisions to LCO 3.4.12 made by TSTF-280, Revision 1, to clarify the application of the available options are not needed due to the changes made to the LCO to reflect the North Anna analysis and design.

8. The North Anna PORVs are supplied from both the Instrument Air System and backup nitrogen accumulators during power operation and from the backup nitrogen 3

accumulators in the LTOP conditions. Therefore, the backup nitrogen accumulators are needed for PORV OPERABILITY. A Surveillance is added to verify the OPERABILITY of the backup nitrogen supply. Subsequent items are renumbered as needed.

North Anna Units 1 and 2 Page 2 Revision 13

Specifications Affected:

ITS 3.4.8 Description The title for the ITS 3.4.8 LCO Notes is revised from "NOTE" to "NOTES" to reflect that there are two LCO Notes. The ISTS markup is correct.

RCS Loops-MODE 5, Loops Not 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 -----------------

I R13

1. All RHR pumps may be removed from operation for 3.

15 minutes when switching from one loop to another provided:

a. The core outlet temperature is maintained > 10OF below 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.

R13

2. One RHR loop surveillance OPERABLE and may be inoperable for

2 testing provided that the in operation.

hours for other RHR loop is 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.

Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 Filled 3.4.8 5-1 R4 3.4.8-1

Specifications Affected:

ITS 3.4.18 Bases Description The LCO Bases for ITS 3.4.18 contained the statements, "Because the water in the RCS is used to fill the loop, it is not necessary to establish limits on the isolated loop water boron concentration or temperature. However, if both isolation valves are not opened within two hours, changes in water boron concentration in the isolated portion of the loop may occur and it is necessary to verify the boron concentration or close the hot leg and cold leg isolation valves and follow the requirements of the LCO to reopen them." These statements are not in the ISTS.

These statements are not consistent with the Required Actions and Surveillance Requirements and have been deleted.

A typographical error is corrected in the first paragraph of the LCO Bases for ITS 3.4.18. The word "values" is changed to the correct word "valves." The ISTS Bases markup does not require 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 conditions for opening the valves are established.

IR13 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 method, the water in the RCS is used to fill the isolated portion of the loop. The LCO also requires that the 1R13 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)

Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 B 3.4.18-3

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 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 method, the water in the RCS is used to fill the isolated portion of the loop. The LCO also requires that the 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 the isolated loop, the RCP seals must be filled with water. The boron concentration of the water used for seal injection must meet the same requirements as the reactor coolant system and the loop must be drained prior to starting seal injection in order to be sure that no water at a boron concentration less than required remains in the isolated loop.

The LCO is modified by a Note which allows a hot or cold leg isolation valve to be closed for up to two hours without considering the loop isolated and meeting the LCO requirements when opening the closed valve. This allows for necessary maintenance and testing on the valves and the valve operators. If the closed valve is not reopened with two hours, it is necessary to close both isolation valves on the affected loop and follow the requirements of the LCO when reopening the isolation valves. This is required because there is a possibility that the water in the isolated loop has become diluted or cooled to the point that reintroduction of the water into to the reactor vessel could result in a significant reactivity change.

Revision 13 North Anna Units 1 and 2 Revision 13 Insert to Page B 3.4-104

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected:

ITS 3.5.2 Bases Description The Bases Background of ITS 3.5.2 state that the shift from cold leg recirculation to hot leg recirculation occurs approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months after an accident. The analyses have been revised and the swap to hot leg recirculation now occurs within approximately 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . The ITS Bases 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 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)

Rev 13 (Draft 2), 01/25/02 North Anna Units 1 and 2 R13 B 3.5.2-1

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 than the capability of the normal charging system:

I-j ý

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 r 1,V and!?a 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)

Rev 1. 04/07/95 WOG STS B 3.5-10

Specifications Affected:

ITS 3.5.6 Bases Description The ITS and ISTS LCO Bases for ITS 3.5.6 state, "It should be noted, however, that changes to applicable MODES cannot be made until the BIT is restored to OPERABLE status pursuant to the provisions of LCO 3.0.4." The changes made to LCO 3.0.4 by TSTF-359, which is incorporated in the North Anna ITS, make this statement inaccurate. It is revised to state, "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." This affects the ITS Bases and ISTS markup. Bases JFD 9 is added to discuss the change.

BIT B 3.5.6 BASES ACTIONS (continued)

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, 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.

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 REQUIREMENTS SR 3.5.6.1 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.

Rev 13 (Draft 1), 01/09/02 R13 North Anna Units 1 and 2 B 3.5.6-4

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 status is consistent with other Completion Times estab]_she.

for loss of a safety function and ensures that 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 the e

/)

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 as cannot be made until the BIT is restored to OPERABLE status 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 dr operators.

(continued)

Rev 1, 04/07/95 B 3.5-39 WOG STS

JUSTIFICATION FOR DEVIATIONS ITS 3.5.6 BASES - BORON INJECTION TANK

1. North Anna does not use 'the system name, "Boron Injection System" and it has been removed from the Bases.

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

3. Editorial change made for enhanced clarity or to be consistent with the ISTS Writers Guide.

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

5. The Boron Injection Tank volume and usable volume are the same. Changes are made to the Bases to reflect the design.

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

7. Changes are made to describe specific assumptions made regarding Boron Injection Tank boron concentration for specific analyses.

8. The LCO paragraph, "If the equipment used to verify BIT parameters (temperature, volume, and boron concentration) is determined to be inoperable, then the BIT is also inoperable," is not adopted. Surveillances use this equipment to verify these parameters are within limits at appropriate frequencies. They are required to verify that the BIT is OPERABLE, but their inoperability does not render the BIT inoperable. The BIT is considered capable of performing it's safety function as long as the Surveillance Requirements for these parameters have been met within the required Frequencies. This is consistent with the use of equipment used to perform surveillances in other sections of NUREG-1431.

9. The Bases to ACTIONS B.1, B.2, and B.3 ends with the statement, "It should be noted, however, that changes to applicable MODES cannot be made until the BIT is restored to OPERABLE status pursuant to the provisions of LCO 3.0.4." Revisions made to LCO 3.0.4 have made this statement incorrect. The statement is revised to state," 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." This statement is consistent with LCO 3.0.4 requirements.

North Anna Units 1 and 2 Page 1 Revision 13

Summary of Changes to the NAPS ITS Submittal Miscellaneous Changes Specifications Affected:

ITS 3.6.7 Bases Description The LCO Bases of ITS 3.6.7 do not describe what constitutes an OPERABLE Recirculation Spray (RS) system. A description of what constitutes an OPERABLE RS System is added to the ITS 3.6.7 LCO Bases for consistency with NEI 01-03, "Writer's Guide for the Improved Standard Technical Specifications," section 4.2.4. A discussion of the impact of the Quench Spray System and casing cooling inoperability on RS OPERABILITY is also added to the LCO Bases. The information added to the LCO Bases is taken from the Background section of the Bases. This affects the ITS Bases, the ISTS Bases markup, and added JFD 12.

RS System B 3.6.7 BASES APPLICABLE SAFETY ANALYSES (continued) the containment atmosphere temperature exceeds the containment design temperature is short enough that there would be no adverse effect on equipment inside containment.

Therefore, it is concluded that the calculated transient containment atmosphere temperatures are acceptable for the SLB and LOCA.

The RS System actuation model from the containment analysis is based upon a response time associated with exceeding the High-High containment pressure signal setpoint to achieving full flow through the RS System spray nozzles. A delay in response time initiation provides conservative analyses of peak calculated containment temperature and pressure. The RS System's total response time is determined by the delay timers and system 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 satisfies Criterion 3 of 10 CFR 50.36(c) (2)(ii).

LCO During a DBA, one train (one inside and one outside RS subsystem in the same train) or two outside RS subsystems of the RS System are required to provide the minimum heat removal capability assumed in the safety analysis. To ensure that this requirement is met, four RS subsystems and the casing cooling tank must be OPERABLE. This will ensure that at least one train will operate assuming the worst case single failure occurs, which is no offsite power and the loss of one emergency diesel generator. Inoperability of the casing cooling tank, the casing cooling pumps, the casing cooling valves, piping, instrumentation, or controls, or of the QS System requires an assessment of the effect on RS subsystem OPERABILITY.

Each RS train consists of one RS subsystem outside containment and one RS subsystem inside containment. Each RS subsystem includes one spray pump, one spray cooler, one (continued)

Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 I R13 B 3.6.7-4

RS System B 3.6.7 BASES LCO (continued)

APPLICABILITY 1800 coverage spray header, nozzles, valves, piping, instrumentation, and controls to ensure an OPERABLE flow path capable of taking suction from the containment sump.

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.

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 status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The components in this degraded (continued)

RAI I 3.6.7-4 IR1 Rev 13 (Draft 1), 01/08/02 North Anna Units 1 and 2 I R13 ACTIONS B 3.6.7-5

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 provides conservative analyses of S~peak calculated containment temperature and pressure.

The RS S stem's total res onse ti 1 ni econ s_

ise siJ nl*.

mna elay ýjese

ýenera~tyr st+ Bin ti nedn 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 A 0

ý,A2*- leR5...

.rl

-q LCO During a DBA, one train e esstem) of 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 asing cooling tank]must be OPERABLE. -This will ensure that at least one (j-- K3 train will operate asuminc the worst case single failure occurs. which is(

v up*

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.

no

_\\,-ý o *r %

S~(continued)

WOG STS B 3.6-103 Rev 1. 4/0/9 I?'I3

ITS 3.6.7 BASES, RECIRCULATION SPRAY SYSTEM INSER Inoperability of the casing cooling tank, the casing cooling pumps, the casing cooling valves, piping, instrumentation, or controls, or of the OS system requires an assessment of the effect on RS subsystem OPERABILITY.

Each RS train consists of one RS subsystem outside containment and one RS subsystem inside containment. Each RS subsystem includes one spray pump, one spray cooler, one 1800 coverage spray header, nozzles, valves, piping, instrumentation, and controls to ensure an OPERABLE flow path capable of taking suction from the containment sump.

North Anna Units 1 and 2 Insert to Page B 3.6-103 Revision 13

JUSTIFICATION FOR DEVIATIONS ITS 3.6.7 BASES, RECIRCULATION SPRAY SYSTEM generator. References to the worst case single active failure are modified to reflect this plant specific assumption.

10. In ISTS 3.6.6E Background and Action A.1 Bases sections, the word "approximately" is added to "50%" and "150%," respectively. This is in reference to the RS heat removal capability of one RS subsystem and 3 RS subsystems, respectively. The exact capacity for each RS subsystem varies, but is approximately 50%. Adding this change makes the statements more accurate.

11. Information is added to the Bases for ITS Required Action D.1 to clarify available RS cooling capability when the casing cooling tank is inoperable.

12. Information is added to the LCO Bases to clearly define what is required for an OPERABLE RS subsystem in accordance with the ITS Writer's Guide.

13. The Bases are revised to refer to the ASME Code and reference the "ASME Code for Operation and Maintenance of Nuclear Power Plants" when discussing the Inservice Testing Program, instead of referencing Section XI of the ASME Code and "ASME, Boiler and Pressure Vessel Code,Section XI." North Anna has adopted the ASME Code for Operation and Maintenance of Nuclear Power Plants, the 1995 Edition and the 1996 Addenda, as required by 10 CFR 50.55a(b)(3). With this adoption, references to Section XI and to the ASME Boiler and Pressure Vessel Code are incorrect when discussing the Inservice Testing Program in the North Anna ITS and Bases.

North Anna Units I and 2 Page 2 Revision 13

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, Request Acceptance... Administration Questions Answers Results Approval Other: ML020650715, ML020840253, ML021220053, ML021220061, ML021220067, ML021220088, ML021220108, ML021220166, ML021220192, ML021220214, ML021220221, ML021220224, ML021220254, ML021550518
MONTHYEAR2002-02-20 [Table View]

ML020510089

Text

Subject:

3.6.3 APPLICABILITY

3.4.3 APPLICABILITY

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