Text

Proposed Improved Technical Specifications Request for Additional Information, ISTS 3.7.7 Beyond Scope Issue
	ML020870707
Person / Time
Site:	North Anna
Issue date:	03/26/2002
From:	Hartz L; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	01-560E, TAC MB1439, TAC MB1440
	Download: ML020870707 (96)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 26, 2002 U.S. Nuclear Regulatory Commission Serial No.:

01-560E 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)

ISTS 3.7.7 BEYOND SCOPE ISSUE (TAC Nos. MB1439 and MB1440)

This letter transmits a revision to the North Anna Power Station (NAPS) Units 1 and 2 proposed Improved Technical Specifications (ITS).

The North Anna ITS license amendment request was submitted to the NRC in a December 11, 2000 letter (Serial No.00-606).

In one letter dated September 6, 2001, and in several telephone conferences over the past seven months, the NRC has requested additional information on the relocation of the Component Cooling (CC) specification to the Technical Requirements Manual (TRM) (TAC Nos. MB1439 and MB1440). Dominion responded to the NRC's RAIs during the telephone conferences and in letters dated November 19, 2001, January 25, 2002, February 18, 2002, March 7, 2002, and March 22, 2002 (Serial Nos.01-560 through 01-560D).

In a telephone conference on March 21, 2002, the NRC informed Dominion that their review to support relocating the CC specification could not be completed in the time frame established by Dominion for ITS implementation. Therefore, Dominion decided to withdraw the request to relocate the CC system, add the current CC Technical Specification requirements for Modes 1 through 4, and pursue relocation of the CC system at a later date. With these revisions to the ITS submittal, the NRC stated that they would issue the ITS amendment the week of April 8, 2002.

This letter transmits the revised pages of the submittal, and the revised pages of the Discussions of Changes tables.

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: O1-560E Docket Nos.: 50-338/339

Subject:

ITS RAI - ISTS 3.7.7 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 2 6th day of March, 2002.

My Commission Expires: March 31, 2002.

Notary Public (SEAL)

Attachment Proposed Improved Technical Specifications Beyond Scope Issue TAC Nos. MB1439 and MB1440 ITS 3.7.19, "Component Cooling" Virginia Electric and Power Company (Dominion)

North Anna Power Station Units 1 and 2

North Anna Improved Technical Specifications (ITS) Request for Additional Information Component Cooling Water (CC) System (TAC Nos. MB13439, MB13440)

In a telephone conference on March 21, 2002, the NRC informed Dominion that their review to support relocating the Component Cooling Water (CC) System specification could not be completed in the time frame established by Dominion for Improved Technical Specification (ITS) implementation. Therefore, Dominion decided to withdraw the request to relocate the CC system, add the current Technical Specification (CTS) CC requirements for Modes 1 through 4 to the ITS, and pursue relocation of the CC system at a later date. In accordance with the NRC's recommendation, we have adopted the CTS requirements for CC with the minimum number of changes required to be consistent with the ITS.

The decision to not pursue relocation of the CC LCO at this time resulted in a number of changes to the ITS submittal:

A new specification, ITS 3.7.19, "Component Cooling Water (CC) System," is added to the Section 3.7 of the ITS. Corresponding Bases are also added. This results in the addition of Justification for Deviations (JFDs) for the Improved Standard Technical Specifications (ISTS) and Bases, markup of Unit 1 and Unit 2 CTS 3.7.3.1, and associated Discussion of Changes (DOCs).

"* The existing Unit 1 and Unit 2 CTS markup and DOC for the relocation of CTS 3.7.3.1 is deleted.

The addition of CC to the ITS, a system shared by Units 1 and 2, requires its addition to the discussion of shared systems in the Bases of ITS 3.3.5, 3.8.1, 3.8.4, and 3.8.9. This affects the typed ITS Bases and the ISTS Bases markup. In addition, those JFDs and DOCs which discuss the shared systems are also affected: ITS 3.8.1, JFD 12 and ITS 3.8.1 DOCs A.2, A.9, A.19, and L. 11, and ITS 3.8.9 DOC A.5.

ADDITION OF SPECIFICATION 3.7.19

CC System 3.7.19 3.7 PLANT SYSTEMS 3.7.19 Component Cooling Water (CC)

System LCO 3.7.19 APPLICABILITY:

Three CC subsystems shall be OPERABLE.

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required CC A.1 Restore required CC 7 days subsystem inoperable, subsystem to OPERABLE status.

B.

Required Action and B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A AND not met.

B.2 Be in MODE 5.

30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months C.

Two required CC C.1 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsystems inoperable.

AND C.2 Initiate actions to be 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months in MODE 5.

D.

No CC water available D.1 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to supply the residual heat removal heat AND exchangers.

D.2 Implement an alternate Immediately means of decay heat removal.

AND D.3 Initiate actions to be Immediately in MODE 5.

Rev 19 (Draft 1),

03/22/02 R19 North Anna Units 1 and 2 3.7.19-1

CC System 3.7.19 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.19.1 Verify each CC manual, power operated, and 31 days automatic valve in the flow path servicing the residual heat removal system, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Rev 19 (Draft 1),

03/22/02 R19 North Anna Units 1 and 2 3.7.19-2

CC System R19 B 3.7.19 B 3.7 PLANT SYSTEMS B 3.7.19 Component Cooling Water (CC)

System BASES BACKGROUND The CC System provides a heat sink for the removal of process and operating heat from components during normal operation.

The CC System serves as a barrier to the release of radioactive byproducts between potentially radioactive systems and the Service Water System, and thus to the environment.

The CC System consists of four subsystems shared between units. Each subsystem consists of one pump and one heat exchanger. The design basis of the CC System is a fast cooldown of one unit while maintaining normal loads on the other unit. Three CC subsystems are required to accomplish this function. With only two CC subsystems available, a slow cooldown of one unit while maintaining normal loads on the other unit can be accomplished. The removal of normal operating heat loads (including common systems) requires two CC subsystems. During normal operation, the CC subsystems are cross connected between the units with two CC pumps and four CC heat exchangers in operation. Two pumps are normally running, with the other two in standby. A vented surge tank common to all four pumps ensures that sufficient net positive suction head is available.

The CC System serves no accident mitigation function and is not a system which functions to mitigate the failure of or presents a challenge to the integrity of a fission product barrier. The CC System is not designed to withstand a single failure. The CC System supports the Residual Heat Removal (RHR)

System. The RHR system does not perform a design basis accident mitigation function.

Additional information on the design and operation of the system, along with a list of the components served, is presented in the UFSAR, Section 9.2.2 (Ref.

1). The principal function of the CC System is the removal of decay heat from the reactor via the Residual Heat Removal (RHR)

System.

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.7.19-1

CC System B 3.7.19 BASES APPLICABLE SAFETY ANALYSES LCO The CC System serves no accident mitigation function. The CC System functions to cool the unit from RHR entry conditions (Tcold < 350°F), to Tcold < 140 0F. The time required to cool from 350°F to 140°F is a function of the number of CC and RHR trains operating. The CC System is designed to reduce the temperature of the reactor coolant from 35 0 °F to 140 OF within 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months based on a service water temperature of 95°F and having two CC subsystems in service for the unit being cooled down.

The CC System has been identified in the probabilistic safety assessment as significant to public health and safety. The CC System satisfies Criterion 4 of 10 CFR 50.36(c) (2) (ii).

Should the need arise to cooldown one unit quickly while the other unit is operating, three CC subsystems would be needed

- two to support the quick cooldown of one unit and one to support the normal heat loads of the operating unit. To ensure this function can be performed a total of three CC subsystems shared with the other unit are required to be OPERABLE.

A CC subsystem is considered OPERABLE when:

a.

The pump and common surge tank are OPERABLE; and

b. The associated piping, valves, heat exchanger, and instrumentation and controls required to perform the function are OPERABLE.

Each CC subsystem is considered OPERABLE if it is operating or if it can be placed in service from a standby condition by manually unisolating a standby heat exchanger and/or manually starting a standby pump.

APPLICABILITY In MODES 1, 2, 3,

operating system.

to perform its RCS by cooling the RHP and 4, the CC System is a normally In MODE 4 the CC System must be prepared heat removal function, which is achieved heat exchanger.

In MODE 5 or 6, the OPERABILITY requirements of the CC System are determined by the systems it supports.

Rev 19 (Draft 1), 03/22/02 R19 North Anna Units 1 and 2 B 3.7.19-2

CC System R19 B 3.7.19 BASES ACTIONS A.1 If one required CC subsystem is inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CC subsystems are adequate to perform the heat removal function. The 7 day Completion Time is reasonable, based on the redundant capabilities afforded by the OPERABLE subsystems.

B.1 and B.2 If the required CC subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-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.

C.1 and C.2 If two required CC subsystems are inoperable, action must be taken to cool the unit to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Action must be initiated to place the unit in MODE 5, where the LCO does not apply, within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 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.

D.1 and D.2 With no CC water available to supply the residual heat removal heat exchangers, action must be taken to cool the unit to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Alternate means to cool the unit must be found and the unit placed in MODE 5, where the LCO does not apply. 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.

Rev 19 (Draft 1),

03/22/02 North Anna Units 1 and 2 B 3.7.19-3

CC System R19 B 3.7.19 BASES SURVEILLANCE SR 3.7.19.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the CC flow path to the RHR heat exchangers provides assurance that the proper flow paths exist for CC operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

REFERENCES

1. UFSAR, Section 9.2.2.

Rev 19 (Draft 1),

03/22/02 North Anna Units 1 and 2 B 3.7.19-4

CC/Syste "

3.7 PLANT SYSTEMS 3.7 1ýComponent Cooling Water (CCý)

System LCO 3.7ý M C shall be OPERABLE.

APPLICABILITY:

ACTIONS MODES 1. 2. 3. and 4.

Rev 1. 04/07/95 Rev, 19c, 3.7,72.I A10101.

(

A, '- 1, C-

~hours 2

WOG STS 3.7-17

ITS 3.7.19, COMPONENT COOLING WATER SYSTEM INSERT C.

Two required CC C.1 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsystems inoperable.

AND C.2 Initiate actions to be in 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months MODE 5.

D.

No CC water available to D.1 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months supply the residual heat removal heat exchangers.

AND D.2 Implement an alternate Immediately means of decay heat removal.

AND D.3 Initiate actions to be in Immediately MODE 5.

North Anna Units 1 and 2 Insert to Page 3.7-17 Revision 19 piq North Anna Units 1 and 2 Insert to Page 3.7-17 Revision 19

System

0) 3.7 (f 0

t"Q SR 3.7S.

NOTE---------

iIsolation CCW flow to indivi a]

( compon s does not render th CCW System inopn able.

S',

4 A Verify each C9manual, ower operated and automatic valve in l.ow path a* F M,

that is not Tocked, sealed, or otherwise secured in position, is in the correct position.

3.7-18 Rev 1. 04/07/95 Rw i WOG STS

>t,?,3.

JUSTIFICATION FOR DEVIATIONS ITS 3.7.19, COMPONENT COOLING WATER SYSTEM

1. The CTS requires three of the four CC subsystems to be OPERABLE. The CC System at North Anna does not perform any accident mitigation functions. Its primary safety function is to provide cooling water to the Residual Heat Removal (RHR) heat exchangers and three CC subsystems are required to support a quick cooldown on one unit and normal operating heat loads on the other unit. The ISTS has been changed to reflect the CTS requirements.

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. The ISTS allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable CC train. The CTS allows 7 days to restore one inoperable CC subsystem. The CTS Completion Time is adopted for the ITS.

The Completion Time is appropriate because the two remaining OPERABLE subsystems are capable of removing the normal operating heat loads of two units and can support a slow cooldown of one or both units.

4. Two new Conditions are added to the ITS, consistent with the CTS. Condition C is added for two CC subsystems inoperable, consistent with the CTS actions. With two required CC subsystems inoperable, normal operating heat loads cannot be removed for two operating units. Cooldown to MODE 4 is necessary to reduce the operating heat loads. In this condition, one or more RHR trains are inoperable. Therefore, it is P11 necessary to initiate and continue actions to cooldown to a MODE in which the LCO is not applicable. Condition C allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach MODE 4. Action must be initiated within an additional one hour to implement a method of moving the unit out of the MODES of applicability (i.e., to MODE 5) and Actions must continue until the Applicability is exited. Condition D is added for no CC water available to the RHR heat exchangers. With no CC water available to the RHR heat exchangers, the RHR trains are inoperable. Cooldown to MODE 4 is necessary to reduce the operating heat loads. In addition, it is necessary to implement an alternate decay heat removal mechanism and cooldown to MODE 5, in which the LCO is not applicable. These Conditions are consistent with the CTS.

5. The CC System does not contain any automatic valves that actuate to perform a function assumed in the safety analysis. Therefore, this Surveillance is not included in the ITS.

This change is consistent with the CTS.

6. The CC pumps do not actuate to perform a function assumed in the safety analysis.

Therefore, this Surveillance is not included in the ITS. This change is consistent with the CTS.

7. ISTS 3.7.7 has been renumbered to ITS 3.7.19. An ITS LCO on CC was added after development of the remainder of the ITS. The specification was placed at the end of Section 3.7 to avoid revision to the remainder of the 3.7 specifications.

North Anna Units 1 and 2 Page 1 Revision 19 North Anna Units I and 2 Page I Revision 19

JUSTIFICATION FOR DEVIATIONS ITS 3.7.19, COMPONENT COOLING WATER SYSTEM

8. ISTS 3.7.7 allows 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to be in MODE 5 when one inoperable CCW train is not restored to OPERABLE status within the Completion Time. CTS 3.7.3.1 allows 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months to be in MODE 5 in the same condition. The CTS Completion Time of 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months is adopted in the ITS.

9. ISTS SR 3.7.7.1 requires verification of the CC flow path and contains a Note which states that isolation of CC flow to individual components does not render the CCW system inoperable. CTS Surveillance 4.7.3.1.a requires verification of the CC flow path to the RHR system. ITS SR 3.7.19.1 requires verification of the CC flow path to the RHR system and does not contain the ISTS Note. This is consistent with the CTS and the North Anna design. The primary function of CC is to supply cooling water to the RHR heat exchangers. The SR verifies that function. The ISTS Note would allow CC to be isolated from RHR and CC to still be considered OPERABLE. That is inconsistent with the North Anna design and CTS.

10. ISTS 3.7.7, Required Action A.1 is modified by a Note which directs entry into the applicable Conditions and Required Actions of LCO 3.4.6 for RHR loops made inoperable by CC. This Note does not appear in the ITS. ITS Condition D addresses CC unavailability to the RHR system. This is consistent with the CTS.

North Anna Units 1 and 2 Page 2 Revision 19 North Anna Units I and 2 Page 2 Revision 19

C _System

)

B 3.7 PLANT SYSTEMS B 3.7.

Component Cooling Water (CW)<System BASES BACKGROUND The CV1 ystem provides a heat sink for he removal of process and operating heat fromda rel

-cornone during (aD,

-B*31a~sis AgtrýMet (DBA,m'ransi '

-nt 1Ifinn*,

normheoptaiq

-niý System alsq,,Kovides this :untion*

_p-*-ova s

emSia cjpmponep:t-ý, as well_ as thefspe~nt,*

fue-s~to~ra e

~

e system serves as a barrier toh re ease o oactive byproducts between potentially radioactive systems and the Service Water System. and thus to the environment.

A typical CCW System*" arranged as two indepen

t. full capacity cooling 1 ps. and has isolatable no fety related components.

Eac Ksafety related train incl s a full 77 capacity pump.

urge tank, heat exchanger.

iping. valves.

and instrumenation.

Each safety relat train is powered from a sep ate bus.

An open surge ta in the system provides ump trip protective functi s to ensure that suffi nt net positive suction he is available.

The mp in ch train is automatically s rted on receipt of a s ety injection signal, and a, nonessential compo ts are 4solated.

Additional information on the design and operation of the system, alon with a list of thecomponents served, is pr'esente in

.Section e

9.2.2Y'(Ref. 1).

The principal

)function of the CVSystem is the remova of decay heat fr or via the Residual Heat Removal (RHR)

S stem.

Phis may bj-dOr-in r

or post.)

c coo shutdowr.

APPLICABLE The design ba~tsisof e CCW System is for one W train to SAFETY ANALYSES remove the post s of coolant accident (L

) heat load from the contpýý~mnt sump during the reci ulation phase, with a maxi]J CW temperature of [120 *F (Ref. 2).

The Emergencyrore Cooling System (ECCS),L)Aand containment OPERAIPZFF LOCA each model the ma x)*mand minimum per fg*P ance of the CCW System, r, siectively.

The nnorm*

t erature of the CCW is [80]O. and. during unit c down

MODE 5 (T*d < [200]°F). a/aximum temperature 95 0F i (continued)

WOG STS B 3.7-36 Rev 1. 04/07/95 Re'. 11

ITS 3.7.19, COMPONENT COOLING WATER SYSTEM INSERT The CC System consists of four subsystems shared between units. Each subsystem consists of one pump and one heat exchanger. The design basis of the CC System is a fast cooldown of one unit while maintaining normal loads on the other unit. Three CC subsystems are required to accomplish this function. With only two CC subsystems available, a slow cooldown of one unit while maintaining normal loads on the other unit can be accomplished. The removal of normal operating heat loads (including common systems) requires two CC subsystems. During normal operation, the CC subsystems are cross connected between the units with two CC pumps and four CC heat exchangers in operation.

Two pumps are normally running, with the other two in standby. A vented surge tank common to all four pumps ensures that sufficient net positive suction head is available.

The CC System serves no accident mitigation function and is not a system which functions to mitigate the failure of or presents a challenge to the integrity of a fission product barrier.

The CC System is not designed to withstand a single failure. The CC System supports the Residual Heat Removal (RHR) System. The RHR system does not perform a design basis accident mitigation function.

lNOflfl Anna Units I and 2 Insert to Page B 3.7-36 Revision 19 North Anna Units I and 2 Insert to Page B 3.7-36

C__System B 3.B7.

BASES pperaL1on o

itn cold < LzUUJ1-mis assumes a m mum q.rvi water temperature s

0'95]*F occurring multaneousl S*,wi

ýthe maximum heat l1 ls on the s ~stem...

llq~~~Te li:i.5)¢WSystem satisfies Cri terion of thp,.ýtP>H*cyj-..*o***,L;3*--F-'"

CO The CCW trains are 1i1endent of each other to e degree that each has sepa te controls and power supp*es and the operation ofn oes not depend on the othe In the event of a DBA. on CW train is required to pr de the minimum heat remov capability assumed in the ety analysis for Sthe sys the s to which it supplies cool? g water.

To ensure thisquirement is met, two trains f CCW must be OPERABL At east one CCW train will opera assuming the worst c nigle active failure occurs co *cident with a loss of offsite power.

A CC( r is considered OPERABLE when:

a.

The pump and

!e surge tank are OPERABLE: and

b.

The associated piping. valves, heat exchanger. and instrumentatlon and controls required to perform the fe re-,tdfunction are OPERABLE.

(continued) 0 0

0 Rev 1. 04/07/95 L

P~ 11 WOG STS B 3.7-37

ITS 3.7.19, COMPONENT COOLING WATER SYSTEM INSERT 1 The CC System is designed to reduce the temperature of the reactor coolant from 350OF to 140°F within 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months based on a service water temperature of 951F and having two CC subsystems in service for the unit being cooled down.

INSERT 2 The CC System has been identified in the probabilistic safety assessment as significant to public health and safety.

INSERT 3 p*1 Should the need arise to cooldown one unit quickly while the other unit is operating, three CC subsystems would be needed - two to support the quick cooldown of one unit and one to support the normal heat loads of the operating unit. To ensure this function can be performed a total of three CC subsystems shared with the other unit are required to be OPERABLE.

INSERT4 Each CC subsystem is considered OPERABLE if it is operating or if it can be placed in service from a standby condition by manually unisolating a standby heat exchanger and / or manually starting a standby pump.

North Anna Units 1 and 2 Insert to Page B 3.7-37 Revision 19 North Anna Units I and 2 Insert to Page B 3.7-37 Revision 19

Cý System B 3.7 BASES LCO Cinope~r~aý.

ut does not

ýt the ODPERA BIý,T

<thoeCCW (continued)

Sys I

APPLICABILITY In MODES 1. 2. 3. nd 4. the CC#System is a normally opera ing sys em.

must be re ared to perform itsi M0,0 'i RCS heat removal.

CUC is achieved by cooling the RHR heat exchanger.

4eV*-*

In MODE 5 or 6. the OPERABILITY requirements of the C9ý Sf rctm ir Antarminad hv the sVytems it ciinnnrts CD A.1 Required Action AI is modified by a the applicable nditions and Requiri "RCS Loops- ;DE 4." be entered if results Kan inoperable RHR loop."

B.1 and B.2 V

If the C4 2(9cannot be restored to OPERABLE status within the associated Completion Time. the unit must be placed in a MODE in which the LCO does not apply.

To achieve this status, the unit must be placed in at leas

0 MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 9

urs.

he 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.

(continued)

B 3.7-38 Rev 1. 04/07/95 Rev I ACTIONS WOG STS 0 Qz) 6V

ITS 3.7.19, COMPONENT COOLING WATER SYSTEM INSERT C.1 and C.2 If two required CC subsystems are inoperable, action must be taken to cool the unit to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Action must be initiated to place the unit in MODE 5, where the LCO does not apply, within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 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.

D.1 and D.2 With no CC water available to supply the residual heat removal heat exchangers, action must be taken to cool the unit to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Alternate means to cool the unit must be found and the unit placed in MODE 5, where the LCO does not apply. 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.

North Anna Units 1 and 2 Revision 19 Insert to Page B 3.7-38

CqW9"Syste*

B 3.7k BASES (continued)

SURVEILLANCE REQUIREMENTS SR 3.70.1***

\\This SR isgeified by a Note indi*iZng that the isolatn of the C flow to individual c onents may render th e

compope ts inoperable but doe not affect the OPERAB ITY of th CW System.

Verifying the correct alignmentlJor manual power operated.

and automatic valves in the CX flow pa hv1rovides assurance that the proper flow paths exist for Ccoperation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing.

This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves.

This Surveillance does not require any testing or valve manipulation: rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

This SR verif' proper automatic operation of the C*F valves on a actual or simulated actuation signal.

The CCW Sys tem I*

normally operating system that canno be fully a ctuat* as part of routine testing during nor~f operation.

Thi urveillance is not required for valves at are 1 ed. sealed, or otherwise secured in th required osition under administrative controls.

e [18] month Frequency is based on the need to perf this Surveillance under the conditions that apply duri a unit outage and the potential for an unplanned transien if the Surveillance were performed with the reactor a power.

Operating experience has shown that these omponents usually pass'the Surveillance when performed at he [18] month Frequency.

Therefore( the Frequency is ceptable from a reliability standpoint./*

(continued)

WOG STS B 3.7-39 Rev 1. 04/07/95 Re,, 0,~

c9

CCSystem B 3.7B BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES WOG STS This SR verifies er automatic operation of the CCW pumps n

R p

a 1

e r

on an actual or Oated actuation signal. The CCW System SR an eat a

he a

j e

oni s is a normall perating system that cannot be fully actua S

e0b a

a no a 1 e a ng sYS1 ba sc j

as part of outine testing during normal operation. Th condng

(

fe n hy 1 f ve i

e to pe fo ým i s a t um r i f 1

0 tu un i t (181 mo Frequency is based on the need to perform is 7

r t r t

r.r.ti 1

y du r j n

.h,

" "r,, "

t h

Surv ' lance under the conditions that apply durin unit p

s T

Ct u

s ua lly C

CW mu rs X

morm r

ou ge and the potential for an unplanned trans' t if the smp 1 p r t i ut veillance were performed with the reactor power.

y if thest Operating experience hhas shown that these onents usually r j fu CCW w r.TcS 7Z]

pass the Surveillance when performed at e [181 month r

Frequency. Therefore. the Frequency Xac"*ceptable from a reliability standpoint.

1.

FSAR. Sectioni9.2.2/.

2.

.SARSectioni - D.

B 3.7-40 Rev 1. 04/07/95 1?aQý,I I

JUSTIFICATION FOR DEVIATIONS ITS 3.7.19 BASES, COMPONENT COOLING WATER SYSTEM

1. The CC System at North Anna does not perform any accident mitigation functions. Its primary safety function is to provide cooling water to the Residual Heat Removal (RHR) heat exchangers. Three CC subsystems are required to support a quick cooldown on one unit and normal operating heat loads on the other unit. The ISTS Bases have been changed to reflect the plant-specific licensing and design basis.

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

4. The CC System at North Anna does not provide any accident mitigation functions.

However, the plant-specific probabilistic safety analysis determined that the CC System is significant to public health and safety and the Specification has been retained in the ITS.

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. The ISTS description that the Specification satisfies Criterion 3 has been changed to specify Criterion 4.

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

6. The Bases are modified to eliminate a statement that the CC system is OPERABLE if CC is isolated from other components. This statement is not applicable to the North Anna design nor is it consistent with the North Anna CTS. See ISTS JFD 9. The following statement is added to the Bases, "Each CC subsystem is considered OPERABLE if it is operating or if it can be placed in service from a standby condition by manually unisolating a standby heat exchanger and / or manually starting a standby pump." This statement is taken from CTS 3.7.3.1, footnote *, and is consistent with the North Anna design.

North Anna Units 1 and 2 Page 1 Revision 19 North Anna Units I and 2 Page I Revision 19

ITS 3.7.19, COMPONENT COOLING WATER SYSTEM UNIT 1 North Anna Units 1 and 2 Revision 19 North Anna Units 1 and 2 Revision 19

T 3.7.0 07-17-97 PT ANT SYSTFMS 3/47.

COMPONENT COOT TNG WATER SYSTEM 34J7131 COMPONENT COOT INCG WATER S1 TBSYSTFM - OPERATING LIMITING CONDITION FOR OPERATION 37, 6

3.7.3.1 Thr e ;Qmponent cooling water subsystems~shat th Wit 2)hall be "OPERABL *

')

th subsystem consisting of:

ra.

On e ERABLE component cooling w r ump and,

.. *,*One OPERABLE component cojng water heat exchanger.

APPLICABILITY:

inMODES 1,2,3, or 4.

ACTION "CT/ON

a. With one required component cooling water subsystem inoperable, return the A w component coolin subsystem to OPERABLE status within the next 7 days, or u

A *(,V(*

Xnitý in OT

ý DBY Q

Ithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in OLDOWN A -4 within the following 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:"'ýý

($o (gj a

)th two required component cooling water subsystems inoperable, t jhEl~in in pj(

C 7O-iV

_'-inthm the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and within the next hour, initiate actions SO H

toO Ein and continue untilD is

achieved.

o -_.-

oc h a g r s t c o o l inth ea te r ~ v a i

na l t

...n e x 1 A )

c. With no component cooling water vailable to suly the residua eat removal heat hours and remain inO0 ntil alternate means of decay heat removal can be implemented.

ontinue actions untilq unijO~ in COLQ D

D D

"* For the purpose this Technical Specific on, each subsystem is consider OPERABLE it is operating or if it ca placed in service from a s y condition

(

by man unisolating a standby t exchanger and/or manuall ing a standby uLiwmp.

- For the purpose of servic ater system upgrades associated with the su y and return piping to/from the co nent cooling water heat exchangers (CC which includes encased in concre and exposed piping from 36" headers to the fi isolation valve, the component co ing water subsystems shall be considered OP LE with only one service w r loop to/from the CCHXs, provided all other quirements in this specif tion are met. This condition is permitted two-mes only (once for each SW l

for a duration of up to 35 days each. Durin ch period of operation with o y ne SW loop available to/from the CCHXs, the visions of Specification 3.0.4 not "applicable. Upon completion of the work as ociated with the second 35-day

riod, this footnote will no longer be applicabl./

NORTH ANNA - UNIT 1 3/4 7-17 Amendment No. 159,194, 205 1044PAL

10-1 1-95 PT ANT SYSTEMS 1/-71 COMPONENT COOT ING WATER SYSTEM 3)/4.7-31 COMPONFNT COOT.ING WATFR SIJBSYSTEM -OPERATING SURVEILLANCE REQUIREMENTS 4.7.3.1 Three component cooling water subsystems shall be demonstrated OPERABLE:

a.

At least once per 31 days by verifying that each valve (manual, power operated or automatic) servicing in the flow path of the residual heat removal system that is not locked, sealed, or otherwise secured in position, is in its correct position.

/b.

Each -co~~nent cooling waterpuhall be tested in ac~~dce with cation.0.5 NORTH ANNA - UNIT I 3/4 7-17a Amendment No. 4-9, 194 roo*

2 Wc -

_.Z -- - 3.7,/1 3 7. i'*1

ITS 3.7.19, COMPONENT COOLING WATER SYSTEM UNIT 2 North Anna Units 1 and 2 Revision 19 North Anna Units 1 and 2 Revision 19

PI ANT SYSTFMS 314-13 COMPONENT COOT INGI WATER SYSTEM COMPONENT COOT ING WATER SIBSYSTEM - OPERATING LIMITING CONDITION FOR OPERATION 3.7.3.1 Three component cooling water subsystemsChr th Wlt 1) shall be O P E R A B L/ith h s u b s y s te m c o n s is tin f:

I"-

a. On ERABLE component ling water pump and.

One OPERABLE comp ent cooling water heat e changer.

APPI ICAB

=ITY E

MODES 1, 2, 3, or 4.

ACTION-

a. With one required component cooling water subsystem inoperable, return the component cooling subs stem to OPERABLE status within the next 7 days. or (Dk,-ý ý

ýin01 DB withi thenext 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in(COLQ~

.in the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

0or 009 b W ith two re uired component cooling water subsystems inoperable, uc j

in t

o within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . and within the next hour, initiate%

C-7'/Ova L cton t a

tnits in 4O=LDS-ýýO nd continue untilT SHUTD "s achieved.

c. With no component cooling wate available to su the residual heat removal heat C7-10/Vol 0

exchangers to cool the unit, la_

h tn

., %bt4*DOWR within the next heat 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and remain in until alternate means of decay heat removal can be implemented. Continue actions until@

unitminJ U

C'~~OE 0

9g LI.

-* For the purpose oif,.t~lechnical Specification, eeach s system is considered__,

OPERABLEýt is operating or if it can be placed iservice from a standby con/cm by manitr unisolating a standby heat excha r and/or manually starting *a n y

or te prpose of servira"ce water tem upgrades associat"ed with the supply and re-r piping to/from the componen ooling water heat exchangers (CCHXs) which I -udes encased in concrete and e sed piping from 36" headers to the first isolation lve, the component cooling w r subsystems shall be considered OPERABLE W only one service water loop from the CCHXs, provided all other requiremen in this specification a met. This condition is permitted two times only ( ce for each SW loop) for a ration of up to 35 days each. During each period o operation with only one SW op available to/from the CCHXs, the provisions of S cification 3.0.4 are not app able. Upon completion of the work associated with e second 35-day period, s footnote will no longer be applicable.

NORTH ANNA - UNIT 2 3/4 7-14 Amendment No. 449,--175, 186 (oc? A 1

z 0

S 2,7.7/

07-17-97 31,7,t1q A&f L I

10-11-95 PLANT SYSTEMS 3/4.7.3 COMPONENT COOLING WATER SYSTEM 3/4.7.3.1 COMPONENT COOLING WATER SUBSYSTEM - OPERATING SURVEILLANCE REQUIREMENTS 4.7.3.1 Three component cooling water subsystems shall be demonstrated OPERABLE:

a.

At least once per 31 days by verifying that each valve (manual, power operated or automatic) servicing in the flow path of the residual heat removal system that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

Each co nent cooling water pump in acco ith

.S i c~ation 4.0.5.

NORTH ANNA - UNIT 2 3/4 7-14a Amendment No. 440, 175

,Qv 19 f

9 e

2I 09 0

DISCUSSION OF CHANGES ITS 3.7.19, COMPONENT COOLING WATER SYSTEM ADMINISTRATIVE CHANGES A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 1, "Standard Technical Specifications Westinghouse Plants" (ISTS).

These changes are designated as administrative changes because they do not result in technical changes to the CTS.

A.2 CTS 3.7.3.1 states that the CC loops are shared by the units. The Applicability applies when either unit is in MODES 1, 2, 3, or 4. Actions a, b, and c contain requirements on both units. ITS 3.7.19 is written to apply to a single unit. The change to the LCO is described in DOC LA. 1. The change to the Applicability and the Actions are administrative changes necessary to be consistent with the change to the LCO. This presentation is also consistent with the presentation used in ITS LCO 3.7.8, Service Water System, which is a similar shared system.

This change is acceptable because both units are required to follow the Technical Specifications and CC is a shared system. If a required CC subsystem is inoperable, both units are affected. The CC applies to each unit that is in the Applicability, so if either unit is in MODE 1, 2, 3, or 4, the CC System is required to be OPERABLE. If one or more CC subsystems are inoperable, ACTIONS must be entered on both units if both are in the Applicable MODES. Therefore, eliminating the cross-unit references is an administrative change. This change is designated as administrative because it does not result in technical changes to the CTS.

A.3 CTS 3.7.3.1 includes footnote "**" which allows a temporary exception to the CC LCO for service water system upgrades. ITS 3.7.19 does not contain that temporary exception.

This change is acceptable because the temporary exception was only allowed to be used two times (once per SW loop). The temporary exception has been used and is no longer valid. This change is designated as administrative because it does not result in technical changes to the CTS.

A.4 CTS 3.7.3.1 Actions refer to CTS MODE names, "Hot Standby," "Hot Shutdown,"

and "Cold Shutdown." ITS 3.7.19 uses the corresponding ITS MODE numbers, "MODE 3," "MODE 4," and "MODE 5." This changes the CTS by utilizing MODE numbers instead of MODE names. Any technical changes associated with the differences in CTS MODES and ITS MODES are discussed in Chapter 1.0.

This change is acceptable because the ITS uses MODE numbers instead of MODE names. Any technical changes associated with the differences in CTS MODES and Revision 19 North Anna Units 1 and 2 Page 1

DISCUSSION OF CHANGES ITS 3.7.19, COMPONENT COOLING WATER SYSTEM ITS MODES are discussed in Chapter 1.0. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA. 1 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.7.3.1 states that three CC subsystems, shared with the other unit, shall be OPERABLE and contains a description of what constitutes an OPERABLE subsystem. Footnote "*" provides further details on what constitutes an operable subsystem. ITS 3.7.19 requires three CC subsystems to be OPERABLE.

This changes CTS by moving the details of what constitutes an OPERABLE subsystem, including that the subsystems are shared between the units, to the Bases.

The removal of these details, which are related to system design, 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 have three OPERABLE CC subsystems and this requirement is sufficient to ensure the CC System can perform its required functions. 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 design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L. 1 (Category 5 - Deletion of Surveillance Requirement) CTS 4.7.3.1.b requires each component cooling water pump to be tested in accordance with Specification 4.0.5.

ITS 3.7.19 does not contain this Surveillance. This changes the CTS by deleting a Surveillance Requirement.

North Anna Units I and 2 Page 2 Revision 19

DISCUSSION OF CHANGES ITS 3.7.19, COMPONENT COOLING WATER SYSTEM The purpose of CTS Specification 4.0.5 is to require inservice testing in accordance with 10 CFR 50.55a. The purpose of inservice testing of the CC pumps is to detect gross degradation caused by impeller structural damage or other hydraulic component problems. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. This change is acceptable because it is not necessary to perform inservice testing of the CC pumps to determine if the pumps are OPERABLE as the pumps are run routinely. Significant degradation of the CC pumps would be indicated by the CC System flow and temperature instrumentation in the Control Room. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

North Anna Units 1 and 2 Page 3 Revision 19 Page 3 Revision 19 North Anna Units I and 2

ELIMINATION OF RELOCATION OF CTS 3.7.3.1

CTS 3.7.3.1, COMPONENT COOLING WATER SYSTEM UNIT 1 North Anna Units 1 and 2

07-17-97

(" PT ANT SY~qTFM.

LIMITING CONDITION FOROERT N

3.7.3.1 Three component oling water subsystems (shared with Unit 2) shall be OPERABLE with ea subsystem consisting of:

a. One OP BLE component cooling water pump and,

b. One ERABLE component cooling water heat exchanger.

."Either Unit in MODES 1, 2,3, or 4.

a ith one required component cooling water subsystem inoperable, return the component cooling subsystem to OPERABLE status within the next 7 days, or place both units in 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 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With two required component cooling water subsystems inoperable, place both its in C HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and within the next hour. initiat actions gi to place both units in COLD SHUTDOWN and continue until COLD SHU OWN is achieved.

c. With no component cooling water available to supply the residual hea emoval heat exchangers to cool the units, place both units in HOT SHUTDOWN" ith~in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and remain in HOT SHUTDOWN until altemate means of d ay heat removal can be implemented. Continue actions until both units are in COL HUTDOWN.

For the purpose of this Technical Specification. each bsystem is considered OPERABLE if it is operating or if it can be placed* service from a standby condition by manually unisolating a standby heat exchan and/or manually starting a standby pump.

- For the purpose of service water system u des associated with the supply and return piping to/from the component cooling w er heat exchangers (CCHXs) which includes encased in concrete and exposed pipi from 36" headers to the first isolation valve, the component cooling water subsyste s shall be considered OPERABLE with only one service water loop to/from the HXs, provided all other requirements in this specification are met. This co ition is permitted two times only (once for each SW loop) for a duration of up to 5 days each. During each period of operation with only one SW loop avail able to/fi h

CHs h poiinso pcfication 3.0.4 are not applicable. Upon compl ion of the work associated with the second 35-day period.

this footnote will no 1o. er be applicable.

NORTH ANNA - UNIT 1 3/4 7-17 Amendment No. 15,9, 205

C 10 31.')*.

10-I I-Q5

[D)/e, 16,4 e Poe-PT ANT gySTFMS azL4IiL COMPONF

('001 INGO WATER S1 TBSYSTEM - OPPRAT :/

SURVEILLANC QUIREMENTS 4.7.3.1 T

e component cooling water subsystems shall be demons ed OPERABLE:

a.

At least once per 31 days by verifying that each val (manual. power operated or automatic) servicing in the flow path of the resi heat removal system that is not locked, sealed, or otherwise secured in positi is in its correct position.

b.

Each component cooling water pump s 1 be tested in accordance with Specification 4.0.5.

NORTH ANNA - UNIT I 3/4 7-17a Amendment No. 4-9, 194

/

pwIc

CTS 3.7.3.1, COMPONENT COOLING WATER SYSTEM UNIT 2

&0q9 North Anna Units 1 and 2 few./ (01 D *-e P3

Ddk+c Pa Cyle CJ5 3~ 7,-5 07-17-97 PI ANT SYSTFMS VA COMPONENT COOT.Q 1RRSYSTEM 3/4-7.3-1 COMPONENT C=O*N WATER ST J11SYSTEM - OPER ATING LIMITING CONDITION FOR9ERATION 3.7.3.1 Three componen cooling water subsystems (shared with Unit 1) shall be OPERABLE a.

a.

b.

C.

- with ec h subsystem consisting of:

One

/ORABLE component cooling water pump and.

One PERABLE component cooling water heat exchanger.

O OPPBE t

opnn roln waeUearxhagr EitherUnit in MODES 1.2.3. or4.

With one required component cooling water subsystem inoperable, return component cooling subsystem to OPERABLE status within the next 7 da or place both units in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD S TDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

With two required component cooling water subsystems inoperab, place both units in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and within the ext hour, initiate actions to place both units in COLD SHUTDOWN and cont' e until COLD SHUTDOWN is achieved.

With no component cooling water available to supply residual heat removal heat exchangers to cool the units, place both units in HO HUTDOWN within the next i-2 hours anu remain in riv1 artU ILJiu WtIN unti Cernate means of uecay heat removal can be implemented. Continue actions til both units are in COLD SHUTDOWN.

For the purpose of this Technical Speci ation. each subsystem is considered OPERABLE if it is operating or if it c be placed in service from a standby condition by manually unisolating a standby at exchanger and/or manually starting a standby pump.

- For the purpose of service water ystem upgrades associated with the supply and return piping to/from the componen ooling water heat exchangers (CCHXs) which includes encased in concrete and ex sed piping from 36" headers to the first isolation valve, itie component cooling wate ubsvstems shall be considered OPERABLE with only one service water loop to/fir m the CCHXs, provided all other requirements in this specificationr met.

is condition is permitted two times only (once for each SW loop) for a durationfup to -35 days each. During each period of operation with only one SW loop avail le to/from the CCHXs, the provisions of Specification 3.0.4 are not applicable. U completion of the work associated with the second 35-day period, "this footnote Ii no longer be applicable.

NORTH ANNA - UNIT 2 3/4 7-14 Amendment No. 140. 175, 186

?

tO I Jf7 A~q I

I I

10-11-95 PLANT SYSTEMS 3/4.7.3 COMPONENT O

IG WA R

SYSTEM 3/4.7.3.1 COMPONENT OOING WATR SUSYSTEM -OPERATING SURVEILLANCE RE REMENTS Z

4.7.3.1 Three c ponent cooling water subsystems shall be demonstr d OPERABLE:

a.

t least once per 31 days by verifying that each valve anual, power operated or automatic) servicing in the flow path of the residu eat removal system that is not locked, sealed, or otherwise secured in positi'

, is in its correct position.

b.

Each component cooling water pump shal tested in accordance with

.Specification 4.0.5.

NORTH ANNA - UNIT 2 3/4 7-14a Amendment No. 440, 175

D el e...A DSCUSSION OF CHANGES CTS 3.7.3.1, COMPONENT COOLING WATER SYSTEM RELOCATED SPECIFICATIONS R. 1 CTS 3.7.3.1 states that three component cooling (CC) water system loops shall be OPERABLE. It is applicable when either unit is in MODES 1, 2, 3, or 4. The primary function of the CC System is to provide cooling water to the Residual Heat Removal (RHR) heat exchangers. Unlike other Westinghouse plants, the RHR at North Anna Power Station (NAPS) does not share components with the Emergency Core Cooling System (ECCS), and thus does not play a role in DBA mitigation. At NAPS, this post-accident heat removal function is provided primarily by the Recirculation Spray System and the Low Head Safety Injection pumps. For this reason, CC is not required for DBA mitigation, and, like RHR, does not meet Criterion 3 of 10 CFR 50.36(c)(2)(ii) for retention in the Technical Specifications for MODES 1, 2, 3, and 4.

Other plants use CC for DBA mitigation functions other than ECCS, such as containment cooling, but the CC system at NAPS does not. This makes the CC System at NAPS different from the CC System described in the ISTS, and retaining the CC requirement for supporting RHR or any other components not assumed in DBA analysis is inappropriate. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

This change is acceptable because CTS 3.7.3.1 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the ITS.

10 CFR 50.36(c)(2)(ii) Criteria Evaluation:

1.

The CC System is not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The CC System does not meet criterion 1.

2.

The CC System is not a process variable, design feature, or operating restriction that is an initial condition of a DBA or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The CC System does not meet criterion 2.

3.

The CC System is not a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The CC System in MODES 1, 2, 3, or 4 was evaluated in WCAP-1 1618 for the generic Westinghouse plant. WCAP 11618 assumed that the CC System served as a support system to various systems which are assumed to function to mitigate various DBAs. However, at NAPS, the CC System is not assumed to function to mitigate any DBAs.

The CC System does not meet criterion 3.

4.

The CC System is not a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to North Anna Units 1 and 2 Page 1

DISCUSSION OF CHANGES CTS 3.7.3.1, COMPONENT COOLING WATER SYSTEM public health and safety. An evaluation performed by the Company determined that the CC System in MODES 1, 2, 3, or 4 is a non-significant risk contributor to core damage frequency and offsite releases. The CC System is not important for any scenarios modeled for MODES 1, 2, 3, or 4 in the NAPS site-specific PRAs. The CC System in MODES 1, 2, 3, or 4 does not meet criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Component Cooling Subsystem - Operating LCO and associated Applicability, Actions, and Surveillances may be relocated out of the Technical Specifications. The Component Cooling Subsystem - Operating specification will be relocated to the Technical Requirements Manual (TRM). Changes to the TRM will be controlled by the provisions of 10 CFR 50.59. This change is designated as relocation because the LCO did not meet the criteria in 10 CFR 50.36(c)(2)(ii) and has been relocated to the TRM.

North Anna Units I and 2 Page 2 Rai 4efi-0-4 Iree'.

1

REVISION TO ITS 3.3.5, 3.8.1, 3.8.4, AND 3.8.9 TO INCORPORATE REFERENCES TO NEW SHARED SYSTEM, CC

LOP EDG Start Instrumentation B 3.3.5 B 3.3 INSTRUMENTATION B 3.3.5 Loss of Power (LOP)

Emergency Diesel Generator (EDG)

Start Instrumentation BASES BACKGROUND The EDGs provide a source of emergency power when offsite power is either unavailable or is insufficiently stable to allow safe unit operation. Undervoltage protection will generate an LOP start if a loss of voltage or degraded voltage condition occurs on the emergency buses. There are two required LOP start signals for each 4.16 kV emergency bus.

Undervoltage relays are provided on each 4160 V Class 1E bus for detecting a loss of bus voltage or a sustained degraded voltage condition. The relays are combined in a two-out-of-three logic to generate a LOP signal.

A loss of voltage start of the EDG is initiated when the voltage is less than 74% of rated voltage and lasts for approximately 2 seconds. A degraded voltage start of the EDG is produced when the voltage is less than 90% of rated voltage sustained for approximately 56 seconds. The time delay for the degraded voltage start signal is reduced to approximately 7.5 seconds with the presence of a Safety Injection signal for the H and J bus on this unit.

3.3.5-01 R6 One 4160 VAC bus from the other unit is needed to support operation of each required Service Water (SW) pump, Main Control Room/Emergency Switchgear Room (MCR/ESGR)

Emergency Ventilation System (EVS) fan, Auxiliary Building central R19 exhaust fan, and Component Cooling Water (CC) pump.

SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, and CC are shared systems.

The Allowable Value in conjunction with the trip setpoint and LCO establishes the threshold for Engineered Safety Features Actuation System (ESFAS) action to prevent exceeding acceptable limits such that the consequences of Design Basis Accidents (DBAs) will be acceptable. The Allowable Value is considered a limiting value such that a channel is OPERABLE if the setpoint is found not to exceed the Allowable Value during the CHANNEL CALIBRATION.

Note that, although a channel is OPERABLE under these circumstances, the setpoint must be left adjusted to within the established calibration tolerance band of the setpoint (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.3.5-1

LOP EDG Start Instrumentation B 3.3.5 BASES APPLICABLE EDG loading, which does not explicitly account for each SAFETY ANALYSES individual component of loss of power detection and (continued) subsequent actions.

The required channels of LOP EDG start instrumentation, in conjunction with the ESF systems powered from the EDGs, provide unit protection in the event of any of the analyzed accidents discussed in Reference 5, in which a loss of 13.3.5-05 offsite power is assumed.

R6 The delay times assumed in the safety analysis for the ESF equipment include the 10 second EDG start delay, and the appropriate sequencing delay, if applicable. The response times for ESFAS actuated equipment in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation,"

include the appropriate EDG loading and sequencing delay if 3.35-01 applicable.

I R6 The LOP EDG start instrumentation channels satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO for LOP EDG start instrumentation requires that three channels per bus of both the loss of voltage and

.I5 13.3.5-01 degraded voltage Functions shall be OPERABLE in MODES 1, 2, R6 3,

and 4 when the LOP EDG start instrumentation supports safety systems associated with the ESFAS. This is associated 35-1 with the requirement of LCO 3.3.5.a for this unit's H and J R6 buses.

LCO 3.3.5.b specifies that for a required H and/or J bus on the other unit that is needed to support a required shared component for this unit, the LOP EDG start RAI instrumentation for the required bus must be OPERABLE.

The 33.501 other unit's required H and/or J bus are required to be R16 OPERABLE to support the SW, MCR/ESGR EVS, Auxiliary Building R19 central exhaust, and CC functions needed for this unit.

These Functions share components, pumps, or fans, which are electrically powered from both units. A channel is OPERABLE with a trip setpoint value outside its calibration tolerance band provided the trip setpoint "as-found" value does not exceed its associated Allowable Value and provided the trip setpoint "as-left" value is adjusted to a value within the "as-left" calibration tolerance band of the trip setpoint. A trip setpoint may be set more conservative than the trip setpoint specified in the TRM (Ref.

2) as necessary in response to unit conditions. In MODES 5 or 6, the three 3..2-5 channels must be OPERABLE whenever the associated EDG is R16 required to be OPERABLE to ensure that the automatic start of (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units I and 2 B 3.3.5-3

ITS 3.3.5, LOP EDG START INSTRUMENTATION INSERT 1 Undervoltage relays are provided on each 4160 V Class 1 E bus for detecting a loss of bus voltage or a sustained degraded voltage condition. The relays are combined in a two-out-of three logic to generate a LOP signal. A loss of voltage start of the EDG is initiated when the voltage is less than 74% of rated voltage and lasts for approximately 2 seconds. A degraded voltage start of the EDG is produced when the voltage is less than 90% of rated voltage sustained for approximately 56 seconds. The time delay for the degraded voltage start signal is reduced to approximately 7.5 seconds with the presence of a Safety Injection signal for the H and J bus on this unit.

po One 4160 VAC bus from the other unit is needed to support operation of each required k

Service Water (SW) pump, Main Control Room/Emergency Switchgear Room (MCR/ESGR)

Emergency Ventilation System (EVS) fan, Auxiliary Building central exhaust fan, and Component Cooling Water (CC) pump. SW, MCR/ESGR EVS, Auxiliary Building central exhaust systems and CC are shared systems.

INSERT 2 The Allowable Value in conjunction with the trip setpoint and LCO establishes the threshold for Engineered Safety Features Actuation System (ESFAS) action to prevent exceeding acceptable limits such that the consequences of Design Basis Accidents (DBAs) will be acceptable. The Allowable Value is considered a limiting value such that a channel is OPERABLE if the setpoint is found not to exceed the Allowable Value during the CHANNEL CALIBRATION. Note that, although a channel is OPERABLE under these circumstances, the setpoint must be left adjusted to within the established calibration tolerance band of the setpoint in accordance with uncertainty assumptions stated in the referenced setpoint methodology, (as-left-criteria) and confirmed to be operating with the statistical allowances of the uncertainty terms assigned.

North Anna Units 1 and 2 Insert to Page B 3.8-144 Revision 19 Revision 19 Insert to Page B 3.8-144 North Anna Units I and 2

ITS 3.3.5, LOP EDG START INSTRUMENTATION INSERT Ikoa This is associated with the requirement of LCO 3.3.5.a for this unit's H and J buses. LCO 3.3.5.b specifies that for a required H and/or J bus on the other unit that is needed to support a required shared component for this unit, the LOP EDG start instrumentation for the required bus must be OPERABLE. The other unit's required H and/or J bus are required to be OPERABLE to support the SW, MCR/ESGR EVS, Auxiliary Building central exhaust and CC functions needed for this unit. These functions share components, pumps or fans, J*z which are electrically powered from both units.

3..*-J A channel is OPERABLE with a trip setpoint value outside its calibration tolerance band provided the trip setpoint "as-found" value does not exceed its associated Allowable Value and provided the trip setpoint "as-left" value is adjusted to a value within the "as-left" calibration tolerance band of the trip setpoint. A trip setpoint may be set more conservative than the trip setpoint specified in the TRM (Ref. 2) as necessary in response to unit conditions.

?.A'*-z North Anna Units I and 2 Insert to Page B 3.8-146 Revision 19 North Anna Units I and 2 Insert to Page B 3.8-146 Revision 19

AC Sources-Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources-Operating BASES BACKGROUND The unit Class 1E AC Electrical Power Distribution System AC sources consist of the offsite power sources (preferred power sources, normal and alternate(s)), and the onsite standby power sources (Train A(H) and Train B(J) emergency diesel generators (EDGs)).

As required by GDC 17 (Ref.

1),

the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

Additionally, the unit's electrical sources must include electrical sources from the other unit that are required to support the Service Water (SW),

Main Control Room (MCR)/Emergency Switchgear Room (ESGR)

Emergency Ventilation System (EVS),

Auxiliary Building central exhaust system, or R19 Component Cooling Water (CC) safety functions. This requirement could include both of the other unit's offsite circuits and EDGs for this unit.

The onsite Class 1E AC Distribution System is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to one preferred offsite power source and a single EDG.

Offsite power is supplied to the switchyard from the transmission network by several different transmission lines. From the switchyard, two electrically and physically separated circuits provide AC power, through reserve station service transformers (RSSTs),

to the 4.16 kV ESF buses. A detailed description of the offsite power network and the circuits to the Class 1E ESF buses is found in the UFSAR, Chapter 8 (Ref. 2).

An offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF bus(es).

Certain required unit loads are energized in a predetermined sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class 1E Distribution (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8. 1-1

AC Sources-Operating B 3.8.1 BASES LCO (continued)

Offsite circuits consist of 34.5 kV buses 3, 4, and 5 supplying the Reserve Station Service Transformer(s)

(RSST) which feed the transfer buses. The D, E, and F transfer buses supply the onsite electrical power to the four emergency buses for the two units. Unit 1 emergency bus H is fed through the F transfer bus from the C RSST. Unit 1 emergency bus J is fed through the D transfer bus from the A RSST.

Unit 1 station service bus 1B can be an alternate feed for Unit 1 H emergency bus, while Unit 1 J bus may be fed from Unit 2 station service bus 2B. Unit 2 emergency bus H is fed through the E transfer bus from the B RSST. Unit 2 emergency bus J is fed through the F transfer bus from the C RSST.

The RSSTs can be fed by any 34.5 kV bus (3, 4, or 5) provided RSSTs A and B are fed from a different 34.5 kV bus than RSST C. Specific breaker nomenclature for individual circuits may be obtained from drawings in the UFSAR, Chapter 8 (Ref.

2).

Each EDG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage or degraded voltage. This will be accomplished within 10 seconds. Each EDG must also be capable of accepting required loads within the assumed loading sequence intervals, and continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as EDG in standby with the engine hot and EDG in standby with the engine at ambient conditions. Additional EDG capabilities must be demonstrated to meet required Surveillances.

Proper sequencing of loads is a required function for EDG OPERABILITY.

The other unit's offsite circuit(s) and EDG(s) are required to be OPERABLE to support the SW, MCR/ESGR EVS, Auxiliary Building central exhaust, and CC functions needed for this unit. These functions share components, pump or fans, which are electrically powered from both units.

The AC sources in one train must be separate and independent (to the extent possible) of the AC sources in the other train. For the EDGs, separation and independence are complete.

For the offsite AC sources, separation and independence are to the extent practical.

Rev 19 (Draft 1), 03/22/02 R11 R11 R11 R19 North Anna Units I and 2 B 3.8. 1-4

AC Sources-Operating B 3.8.1 BASES ACTIONS C.1 and C.2 (continued) is exited and AOT is restricted by the Completion Time tracked in Condition B. If the AAC DG or one or more of the other unit's EDG(s) becomes inoperable at sometime after the initial EDG inoperability, Condition C requires the restoration of the EDG or the AAC DG and the other unit's 13R8.1-2 EDG(s) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or Condition L is required to be R3 entered.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is considered reasonable and takes into account the assumption in the probabilistic safety analysis (PSA) for potential core damage frequency.

D.1, D.2, and D.3 Condition D is modified by a Note indicating that separate Condition entry is allowed for each offsite circuit on the other unit that provides electrical power to required shared components.

To provide the necessary electrical power for the SW, MCR/ESGR EVS, Auxiliary Building central exhaust, and CC lR19 functions for a unit, AC electrical sources of both units may be required to be OPERABLE.

Action D is entered for one or more inoperable offsite circuit(s) on the other unit that is necessary to support required shared components. These shared components are the SW pump(s),

MCR/ESGR EVS fan(s),

1R19 Auxiliary Building central exhaust fan(s), and CC pumps.

Required Action D.1 verifies the OPERABILITY of the remaining required offsite sources within an hour of the inoperability and every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Since the Required Action only specifies "perform," a failure of the SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

The Completion Time for Required Action D.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. The required shared component has no offsite power; and

b. A required shared component(s) in the same system is 3.8.-35 inoperable.I (conti nued)

Rev 19 (Draft 1), 03/22/02 North Anna Units I and 2 B 3.8.1-11

AC Sources-Operating B 3.8.1 BASES ACTIONS D.1, D.2 and D.3 (continued)

If at any time during the existence of Condition D (one offsite circuit inoperable on the other unit needed to supply electrical power for a required shared component) another required shared component in the same system subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power on the other unit that supports a required shared component and an additional required shared component in the same system inoperable, results in starting the Completion Times for the Required Action.

Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuits and EDGs that power the required shared components are adequate to support the SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, R19 and CC functions. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the remaining shared component(s),

a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Operation may continue in Condition D for a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable on the other unit supplying electrical power to a required shared component, the reliability of the SW, MCR/ESGR EVS, IR19 Auxiliary Building central exhaust system, and CC functions are degraded. The potential for the loss of offsite power to the other required shared components is increased, with the attendant potential for a challenge to SW, MCR/ESGR EVS, !

R19 Auxiliary Building central exhaust system, and CC functions.

The required offsite circuit must be returned to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or the support function for the associated shared component is considered inoperable. At that time, the required shared component must be declared inoperable and the appropriate Conditions of the LCO 3.7.8, "Service Water System," LCO 3.7.10, "MCR/ESGR Emergency Ventilation System," LCO 3.7.12, "Emergency Core Cooling R19 System (ECCS)

Pump Room Exhaust Air Cleanup System," and LCO 3.7.19, "Component Cooling Water (CC)

System," must be entered. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources (continued)

Rev 19 (Draft 1),

03/22/02 North Anna Units 1 and 2 B 3.8.1-12

AC Sources-Operating B 3.8.1 BASES ACTIONS D.1, D.2 and D.3 (continued) providing electrical power to the required shared components, a reasonable time for repairs and the low probability of a DBA occurring during this period of time.

E.1, E.2, and E.3 To ensure a highly reliable power source remains with an inoperable EDG, it is necessary to verify the availability of the required offsite circuits on a more frequent basis.

Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. Required Action E.1 verifies the OPERABILITY of the required offsite sources within an hour of the inoperability and every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must be entered.

Required Action E.2 is intended to provide assurance that a loss of offsite power, during the period that an EDG is inoperable, does not result in a complete loss of the SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, or IR19 CC functions.

I The Completion Time for Required Action E.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. The required shared component with an inoperable EDG; and

b. A required shared component(s) in the same system is 3.8 inoperable.

I.R3 If at any time during the existence of Condition E (one EDG inoperable on the other unit needed to supply electrical power for a required shared component) another required shared component subsequently becomes inoperable, this Completion Time begins to be tracked.

(continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8. 1-13

AC Sources-Operating B 3.8.1 BASES ACTIONS E.1, E.2, and E.3 (continued)

Discovering an EDG on the other unit that supports a required shared component and an additional required shared component inoperable, results in starting the Completion Times for the Required Action. Four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuits and EDGs that power the required shared components are adequate to support the SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, 1R19 or CC functions. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the component OPERABILITY of the remaining shared components, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Operation may continue in Condition E for a period of 14 days. With one EDG inoperable on the other unit supplying electrical power to a required shared component, the reliability of the respective Function is degraded. The potential for the loss of EDGs to the other required shared components is increased, with the attendant potential for a challenge to respective Function.

The required EDG must be returned to OPERABLE status within 14 days, or the support function for the associated shared component is considered inoperable. At that time, the required shared component must be declared inoperable and the appropriate Conditions of the LCOs 3.7.8, 3.7.10,

[19 3.7.12, and 3.7.19 must be entered. The 14 day Completion Time takes into account the capacity and capability of the remaining AC sources providing electrical power to the required shared components, a reasonable time for repairs and the low probability of a DBA occurring during this period of time.

F.I and F.2 To ensure a highly reliable electrical power source remains available when one EDG is inoperable that is required to support a required shared component on the other unit, Condition F is established to monitor the OPERABILITY of the AAC DG and the LCO 3.8.1.b EDGs. Condition F is entered any time an EDG that is required to support a required shared component that receives its electrical power from the other unit becomes inoperable and the Required Actions and (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8. 1-14

AC Sources-Operating B 3.8.1 BASES ACTIONS F.1 and F.2 (continued)

Completion Times are followed. Concurrently, if the AAC DG or one or more of this unit's EDG(s) is inoperable, or become inoperable, in addition to the Required Actions of Condition E, Required Actions F.1 and F.2 limit the time the EDG may be out of service to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If the AAC DG or this unit's EDG(s) is inoperable when the other unit's EDG becomes inoperable, the AOT is limited to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , unless the AAC DG and this unit's EDG(s) are returned to OPERABLE status. If during the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time of F.1 or F.2, the AAC DG and this unit's EDG are return to OPERABLE status, Condition F is exited and AOT is restricted by the Completion Time tracked in Condition E. If the AAC DG or one or more of this unit's EDG(s) becomes inoperable at sometime after the initial EDG inoperability, Condition F requires the restoration of the AAC DG and this unit's EDG(s) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or the supported shared component must be declared inoperable and LCOs 3.7.8, 3.7.10, 3.7.12, and 3.7.19 1R19 provides the appropriate restrictions.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is considered reasonable and takes into account the assumption in the probabilistic safety analysis (PSA) for potential core damage frequency.

G.1 and G.2 Required Action G.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (Required Action A.2).

The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref.

6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE.

When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are powered from redundant AC safety trains.

The Completion Time for Required Action G.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8.1-15

AC Sources-Operating B 3.8.1 BASES ACTIONS 1.1 (continued)

With Train H and Train J EDGs inoperable, there are no remaining standby AC sources. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions.

Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power).

Since any inadvertent generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

According to Reference 6, with both EDGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

J.1 With two LCO 3.8.1.c required EDGs inoperable, as many as two required shared and potentially required components have no remaining standby AC sources. Thus, with an assumed loss of offsite power condition, the required shared components powered from the other unit would be significantly degraded.

Therefore, the required shared component would immediately be declared inoperable and LCOs 3.7.8, 3.7.10, 3.7.12, R3 and 3.7.19 would provide the appropriate restrictions.

R19 K.1 and K.2 Condition K is modified by a Note indicating that separate Condition entry is allowed for each inoperable sequencing timing relay.

Condition K is entered any time a required sequencing timing relay (STR) becomes inoperable. Required Action K.1 directs the entry into the Required Actions and Completion Times associated for the individual component served by the inoperable relay. The instrumentation signals that provide the actuation are governed by LCO 3.3.2, "Engineered Safety Features Actuation System Instrumentation" for safety (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8.1-18

DC Sources-Operating B 3.8.4 BASES BACKGROUND (continued)

APPLICABLE SAFETY ANALYSES Each 125 VDC battery is separately housed in a ventilated room apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other subsystem to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. There is no sharing between redundant Class 1E subsystems, such as batteries, battery chargers, or distribution panels.

The criteria for sizing large lead storage batteries are defined in IEEE-485 (Ref. 5).

Each Train H and Train J DC electrical power subsystem has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged.

Each battery charger also has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the UFSAR, Chapter 8 (Ref. 4).

The EDG DC electrical power system consists of the battery, battery charger, and interconnecting cabling to supply the required DC voltage to allow the associated EDG components to perform the required safety function.

For the other unit, control power for breakers and electrical power for solenoid operated valves that are needed to support operation of each required Service Water (SW) pump, Main Control Room (MCR)/Emergency Switchgear Room (ESGR)

Emergency Ventilation System (EVS) fan, Auxiliary Building central exhaust fan, and Component Cooling Water (CC) pump.

SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, and CC are shared systems.

The initial conditions of Design Basis Accident (DBA) and transient analyses in the UFSAR, Chapter 6 (Ref.

6), and in the UFSAR, Chapter 15 (Ref.

7),

assume that Engineered Safety Feature (ESF) systems are OPERABLE.

The DC electrical power system provides normal and emergency DC electrical power for the emergency auxiliaries and control and switching during all MODES of operation.

(continued)

Rev 19 (Draft 1),

03/22/02 R19 North Anna Units I and 2 B 3.8.4-2

DC Sources-Operating B 3.8.4 BASES APPLICABLE The OPERABILITY of the DC sources is consistent with the SAFETY ANALYSES initial assumptions of the accident analyses and is based (continued) upon meeting the design basis of the unit. This includes maintaining the DC sources OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power; and

b.

A worst case single failure.

The OPERABILITY of the EDG DC electrical power system ensures the EDG may perform its required safety function.

The DC sources satisfy Criterion 3 of 10 CFR

50. 36(c) (2) (ii).

LCO The DC electrical power subsystems, each subsystem consisting of two batteries, battery charger for each battery and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the train are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. Loss of any train DC electrical power subsystem does not prevent the minimum safety function from being performed (Ref. 4).

The EDG DC electrical power system consists of the battery, battery charger, and interconnecting cabling to supply the required DC voltage to allow the associated EDG components to perform the required safety function.

An OPERABLE DC electrical power subsystem requires all required batteries and respective chargers to be operating and connected to the associated DC bus(es).

Additionally, the unit's electrical sources must include DC 3409 sources from the other unit that are required to support the R3 SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, R19 or CC safety functions. Control power for breakers and electrical power for solenoid operated valves are examples of support systems required to be OPERABLE that are needed for the operation of each required SW pump, MCR/ESGR EVS fan, (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8.4-3

DC Sources-Operating B 3.8.4 BASES LCO Auxiliary Building central exhaust fan, and CC pump.

SW, RAI (continued)

MCR/ESGR EVS, Auxiliary Building central exhaust system, and IR39 CC are shared systems.

IR19 APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients; and

b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The EDG DC system is required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure the OPERABILITY of the associated EDG in accordance with LCO 3.8.1. In MODES 5 or 6, the OPERABILITY requirements of the EDG DC system are determined by the EDGs that they support in accordance with LCO 3.8.2.

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources-Shutdown."

ACTIONS A.1 Condition A represents one train with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected train. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC distribution system train.

If one of the required LCO 3.8.4.a DC electrical power subsystems is inoperable (e.g., inoperable battery, inoperable battery charger(s), or inoperable battery charger and associated inoperable battery), the remaining LCO 3.8.4.a DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. For the Station batteries, a spare battery charger may be substituted for the normal charger without (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8.4-4

DC Sources-Operating B 3.8.4 BASES ACTIONS A.1 (continued) entry into Condition A. Since a subsequent worst case single failure would, however, result in the complete loss of the remaining 125 VDC electrical power subsystems with attendant loss of ESF functions, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 8) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

B.1 and B.2 If the inoperable DC electrical power subsystem 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 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. The 1R3 Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 8).

C.1 Condition C represents the loss of the ability of the EDG DC system (e.g., inoperable battery charger or inoperable battery) to supply necessary power to the associated EDG.

In this condition, the associated EDG is immediately declared inoperable and the associated Conditions or Required Actions of LCO 3.8.1 are followed.

D.1 Condition D represents the loss of one or more required LCO 3.8.4.c DC electrical power subsystem(s) needed to support the operation of required shared components on the other unit. SW, MCR/ESGR EVS, Auxiliary Building central IR19 exhaust system, and CC are shared systems. In this condition, the associated required shared components are declared inoperable immediately. The associated Conditions or Required Actions of LCO 3.7.8, "Service Water System,"

(continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units I and 2 B 3.8.4-5

DC Sources-Operating B 3.8.4 BASES ACTIONS D.1 (continued)

LCO 3.7.10, "MCR/ESGR Emergency Ventilation Systems,"

LCO 3.7.12, "Emergency Core Cooling System Pump Room Exhaust Air Cleanup System," and LCO 3.7.19, "Component Cooling Water (CC)

System," are followed.

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS For Station and EDG batteries, verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function.

Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations. The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref.

9).

SR 3.8.4.2 Visual inspection of both Station and EDG batteries to detect corrosion of the battery cells and connections, or measurement of the resistance of each intercell, interrack, intertier, and terminal connection, provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.

The presence of visible corrosion does not necessarily represent a failure of this SR provided visible corrosion is removed during performance of SR 3.8.4.4.

The Surveillance Frequency for these inspections, which can detect conditions that can cause power losses due to resistance heating, is 92 days. This Frequency is considered acceptable based on operating experience related to detecting corrosion trends.

Rev 19 (Draft 1), 03/22/02 R19 North Anna Units 1 and 2 B 3.8.4-6

Distribution Systems-Operating B 3.8.9 BASES BACKGROUND (continued)

APPLICABLE SAFETY ANALYSES LCO For the other unit, one AC and DC bus on that unit is needed to support operation of each required Service Water (SW) pump, Main Control Room (MCR)/Emergency Switchgear Room (ESGR)

Emergency Ventilation System (EVS) fan, Auxiliary Building central exhaust fan, and Component Cooling Water (CC) pump.

SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, and CC are shared systems.

The list of all required distribution buses is presented in Table B 3.8.9-1.

The initial conditions of Design Basis Accident (DBA) and transient analyses in the UFSAR, Chapter 6 (Ref.

1),

and in the UFSAR, Chapter 15 (Ref.

2),

assume ESF systems are OPERABLE.

The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution systems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining power distribution systems OPERABLE during accident conditions in the event of:

a.

An assumed loss of all offsite power or all onsite AC electrical power; and

b.

A worst case single failure.

The distribution systems satisfy Criterion 3 of 10 CFR 50.36(c) (2) (i i).

The required power distribution subsystems listed in Table B 3.8.9-1 ensure the availability of AC, DC, and AC vital bus electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an (continued)

Rev 19 (Draft 1), 03/22/02 R19 North Anna Units 1 and 2 B 3.8.9-2

Distribution Systems-Operating B 3.8.9 BASES ACTIONS C.1 (continued)

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is inoperable and subsequently returned

OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the DC distribution system. At this time, an AC train could again become inoperable, and DC distribution restored OPERABLE.

This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

D.1 With one or more required LCO 3.8.9.b AC electrical power distribution subsystem(s) inoperable, the shared component(s) on the other unit is not capable of operating.

R3 In this condition, the associated shared component is declared inoperable immediately. SW, MCR/ESGR EVS, Auxiliary R19 Building central exhaust system, and CC are shared systems.

The associated Conditions or Required Actions of LCO 3.7.8, "Service Water System,"

LCO 3.7.10, "MCR/ESGR Emergency (continued)

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8.9-8

Distribution Systems-Operating B 3.8.9 BASES ACTIONS D.1 (continued)

Ventilation System," LCO 3.7.12, "Emergency Core Cooling R19 System Pump Room Exhaust Air Cleanup System," and LCO 3.7.19, "Component Cooling Water (CC)

System," are followed.

E.1 With one or more required LCO 3.8.9.b DC electrical power distribution subsystem(s) inoperable, the shared component(s) on the other unit is not capable of operating.

In this condition, the associated shared component is declared inoperable immediately.

SW, MCR/ESGR EVS, Auxiliary 1R19 Building central exhaust system, and CC are shared systems.

The associated Conditions or Required Actions of LCO 3.7.8, 3.7.10, 3.7.12, and 3.7.19 are followed.

1R19 F.1 and F.2 If the inoperable LCO 3.8.9.a distribution subsystem 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 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.

G.1 Condition G corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one inoperable LCO 3.8.9.a electrical power distribution subsystem results in the loss of a required function, the unit is in a 1R3 condition outside the accident analysis. Therefore, no additional time is justified for continued operation.

LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

Rev 19 (Draft 1), 03/22/02 North Anna Units 1 and 2 B 3.8.9-9

JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 - AC SOURCES - OPERATING

7. CTS Surveillance Requirement 4.8.1.1.2.d.10 requires each EDG to be fast started within 5 minutes of shutting down from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of operation loaded between 2500 and 2600 kW or until the EDG obtains stable operating temperatures. ISTS SR 3.8.1.15 is modified to retain the allowance to operate an EDG until "operating temperatures have stabilized," in the ITS SR 3.8.1.14 Note 1. This change is acceptable because the function of the Note is to ensure the EDG is at normal operating conditions before it is shutdown, and restarted within 10-seconds to the required voltage and frequency.

8. ISTS LCO part c, Action F and SR 3.8.1.18 are constructed for a load sequencer that coordinates supplying electrical power for a train of equipment. The assumed type of sequencer operates differently depending on the source of electrical power for the emergency bus (EDG or offsite circuit). Failure of the sequencer would affect all components powered by the emergency electrical bus. Therefore, a sequencer is typically allowed to be inoperable for only 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the same Completion Time allowed for a loss of an EDG concurrent with the loss of an offsite circuit. The North Anna electrical design does not utilizes this type of device, but uses individual sequencing timing relays for each component to be loaded onto an emergency bus. The components served by the sequencing timing relays are not dependent on the source of power supplying the emergency bus. The ITS is modified to reflect the North Anna design. An inoperable sequencing timing relay requires entry into the Condition K. ITS Required Action K. 1 requires the affected system, subsystem, or component to be declared inoperable immediately, while Required Action K.2.1 requires the component be placed in a condition that inhibits the automatic loading to the emergency bus and K.2.2 allows the associated EDG to be declared inoperable. These Required Actions are appropriate to ensure the electrical bus is protected and degraded safety functions are tracked. ITS SR 3.8.1.16 verifies each sequenced load is within design tolerance for each sequencing timing relay every 18 months. This change is acceptable because a sequencing timing relay can affect an individual function and the emergency bus.

9. ISTS SR 3.8.1.10 requires verification every 18 months that each EDG will not trip and will maintain voltage within a maximum limit on a full load rejection test. A full load rejection test is not required by the CTS requirements, and is not included in the ITS requirements. Each EDG will continue to perform the largest post-accident load rejection test every 18 months. This change is acceptable because the North Anna electrical design utilizes a higher current trip on the EDG output breaker than from individual loads. The SRs following ISTS SR 3.8.1.10 are re-numbered to reflect this deletion.

10. Not used.

11. Not used.

12. CTS electrical source requirements for Service Water (SW) and Component Cooling 1I'129 (CC) pumps, Main Control Room/Emergency Switchgear Room fans, and Auxiliary Building central exhaust fans (shared components) are incorporated into the ITS 3.8.1 requirements. The electrical requirements for a unit's shared functions may include North Anna Units I and 2 Page 2 Revision 19

ITS 3.8.1 BASES - AC SOURCES - OPERATING INSERT 1 Additionally, the unit's electrical sources must include electrical sources from the other unit that are required to support the Service Water (SW), Main Control Room (MCR)/Emergency Switchgear Room (ESGR) Emergency Ventilation System (EVS), Auxiliary Building central 1

exhaust system or Component Cooling Water (CC) safety functions. This requirement could include both of the other unit's offsite circuits and EDGs for this unit.

INSERT 2 permanently connected loads and all automatically connected loads, via the load sequencing timing relays, needed to recover the unit or maintain it in a safe condition are energized.

North Anna Units 1 and 2 Insert to Page B 3.8 - 1 Revision 19 North Anna Units I and 2 Insert to Page B 3.8 - I Revision 19

ITS 3.8.1 - AC SOURCES - OPERATING INSERT The other unit's offsite circuit(s) and EDG(s) are required to be OPERABLE to support the SW, MCRPESGR EVS, Auxiliary Building central exhaust and CC functions needed for this 1pICI unit. These functions share components, pumps or fans, which are electrically powered from both units.

North Anna Units 1 and 2 Insert to Page B 3.8-4 Revision 19 North Anna Units I and 2 Insert to Page B 3.8-4 Revision 19

ITS 3.8.1 - AC SOURCES - OPERATING INSERT C.1 and C.2 To ensure a highly reliable electrical power source remains available when one EDG is inoperable, Condition C is established to monitor the OPERABILITY of the AAC DG and the other unit's EDGs. Condition B is entered any time an EDG becomes inoperable and the Required Actions and Completion Times are followed. Concurrently, if the AAC DG or one or more of the other unit's EDG(s) is inoperable, or become inoperable, in addition to the Required Actions of Condition B, Required Actions C.1 and C.2 limit the time the EDG may be out of service to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If the AAC DG or the other unit's EDG(s) is inoperable when the EDG becomes inoperable, the allowed outage time (AOT) is limited to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , unless the AAC DG and the other unit's EDG(s) are returned to OPERABLE status. If during the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time of C.1 or C.2, the AAC DG and the other unit's EDG(s) are return to OPERABLE status, Condition C is exited and AOT is restricted by the Completion Time tracked in Condition B. If the AAC DG or one or more of the other unit's EDG(s) becomes inoperable at sometime after the initial EDG inoperability, Condition C requires the restoration of the AAC DG and the other unit's EDG(s) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or Condition L is required to be entered.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is considered reasonable and takes into account the assumption in the probabilistic safety analysis (PSA) for potential core damage frequency.

D.1. D.2. and D.3 Condition D is modified by a Note indicating that separate Condition entry is allowed for each offsite circuit on the other unit that provides electrical power to required shared components.

To provide the necessary electrical power for the SW, MCR/ESGR EVS, Auxiliary Building central exhaust and CC functions for a unit, AC electrical sources of both units may be required to be OPERABLE. Action D is entered for one or more inoperable offsite circuit(s) on the other unit that is necessary to support required shared components. These shared components are the SW pump(s), MCR/ESGR EVS fan(s), Auxiliary Building central exhaust fan(s), and CC pumps. Required Action D.1 verifies the OPERABILITY of the remaining required offsite sources within an hour of the inoperability and every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Since the Required Action only specifies "perform," a failure of the SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

The Completion Time for Required Action D.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities.

This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. The required shared component has no offsite power; and

,R,4AI

b. A required shared component(s) in the same system is inoperable.

North Anna Units I and 2 Insert to Page B 3.8-11 Revision 19

ITS 3.8.1 - AC SOURCES - OPERATING INSERT (continued)

If at any time during the existence of Condition D (one offsite circuit inoperable on the other unit needed to supply electrical power for a required shared component) another required shared component in the same system subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power on the other unit that supports a required shared component and an additional required shared component in the same system inoperable, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuits and EDGs that power the required shared components are adequate to support the SW, MCR/ESGR EVS, Auxiliary Building central exhaust system and CC functions. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the remaining shared component(s), a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Operation may continue in Condition D for a period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable on the other unit supplying electrical power to a required shared component, the reliability of the SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, and CC functions are degraded. The potential for the loss of offsite power to the other required I,

shared components is increased, with the attendant potential for a challenge to SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, and CC functions.

I IWI The required offsite circuit must be returned to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or the support function for the associated shared component is considered inoperable. At that time, the required shared component must be declared inoperable and the appropriate Conditions of the LCO 3.7.8, "Service Water System," LCO 3.7.10, "MCR/ESGR Emergency Ventilation System," LCO 3.7.12, "Emergency Core Cooling System (ECCS)

Pump Room Exhaust Air Cleanup System," and LCO 3.7.19, "Component Cooling Water 1M (CC) System," must be entered. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources providing electrical power to the required shared components, a reasonable time for repairs and the low probability of a DBA occurring during this period of time.

E.1, E.2, and E.3 To ensure a highly reliable power source remains with an inoperable EDG, it is necessary to verify the availability of the required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. Required Action E.1 verifies the OPERABILITY of the required offsite sources within an hour of the inoperability and every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must be entered.

North Anna Units 1 and 2 Insert to Page B 3.8-11 Revision 19 Revision 19 North Anna Units I and 2 Insert to Page B 3.8-11

ITS 3.8.1 - AC SOURCES - OPERATING INSERT (continued)

Required Action E.2 is intended to provide assurance that a loss of offsite power, during the period that an EDG is inoperable, does not result in a complete loss of the SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, or CC functions.

IR11 The Completion Time for Required Action E.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a.

The required shared component with an inoperable EDG; and

b.

A required shared component(s) in the same system is inoperable.

1.8r If at any time during the existence of Condition E (one EDG inoperable on the other unit needed to supply electrical power for a required shared component) another required shared component subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering an EDG on the other unit that supports a required shared component and an additional required shared component inoperable, results in starting the Completion Times for the Required Action. Four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuits and EDGs that power the required shared components are adequate to support the SW, MCR/ESGR EVS, Auxiliary Building central exhaust system, or CC functions. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the component OPERABILITY of the remaining shared component(s), a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Operation may continue in Condition E for a period of 14 days. With one EDG inoperable on the other unit supplying electrical power to a required shared component, the reliability of the respective Function is degraded. The potential for the loss of EDGs to the other required shared components is increased, with the attendant potential for a challenge to respective Function.

The required EDG must be returned to OPERABLE status within 14 days, or the support function for the associated shared component is considered inoperable. At that time, the required shared component must be declared inoperable and the appropriate Conditions of the LCOs 3.7.8, 3.7.10, 3.7.12 and 3.7.19 must be entered. The 14 day Completion Time takes into account the capacity and capability of the remaining AC sources providing electrical power to the required shared components, a reasonable time for repairs and the low probability of a DBA occurring during this period of time.

North Anna Units 1 and 2 Insert to Page B 3.8-11 Revision 19 North Anna Units I and 2 Insert to Page B 3.8-11 Revision 19

ITS 3.8.1 - AC SOURCES - OPERATING INSERT (continued)

F.1 and F.2 To ensure a highly reliable electrical power source remains available when one EDG is inoperable that is required to support a required shared component on the other unit, Condition F is established to monitor the OPERABILITY of the AAC DG and the LCO 3.8.1.b EDGs. Condition F is entered any time an EDG that is required to support a required shared component that receives its electrical power from the other unit becomes inoperable and the Required Actions and Completion Times are followed. Concurrently, if the AAC DG or one or more of this unit's EDG(s) is inoperable, or become inoperable, in addition to the Required Actions of Condition E, Required Actions F.1 and F.2 limit the time the EDG may be out of service to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If the AAC DG or this unit's EDG(s) is inoperable when the other unit's EDG becomes inoperable, the AOT is limited to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , unless the AAC DG and this unit's EDG(s) are returned to OPERABLE status. If during the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time of F.1 or F.2, the AAC DG and this unit's EDG are return to OPERABLE status, Condition F is exited and AOT is restricted by the Completion Time tracked in Condition E.

If the AAC DG or one or more of this unit's EDG(s) becomes inoperable at sometime after the initial EDG inoperability, Condition F requires the restoration of the AAC DG and this unit's EDG(s) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or the supported shared component must be declared inoperable and LCOs 3.7.8, 3.7.10, 3.7.12 and 3.7.19 provides the appropriate restrictions. * *i1 The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is considered reasonable and takes into account the assumption in the probabilistic safety analysis (PSA) for potential core damage frequency.

North Anna Units 1 and 2 Insert to Page B 3.8-11 Revision 19 North Anna Units I and 2 Insert to Page B 3.8-11 Revision 19

ITS 3.8.1 - AC SOURCES - OPERATING INSERT J.1 With two LCO 3.8.1.c required EDGs inoperable, as many as two required shared and potentially required components have no remaining standby AC sources. Thus, with an assumed loss of offsite power condition, the required shared components powered from the other unit would be significantly degraded. Therefore, the required shared component would immediately be declared inoperable and LCOs 3.7.8, 3.7.10, 3.7.12 and 3.7.19 would IJ?

provide the appropriate restrictions.

K.1 and K.2 Condition K is modified by a Note indicating that separate Condition entry is allowed for each inoperable sequencing timing relay.

Condition K is entered any time a required sequencing timing relay (STR) becomes inoperable. Required Action K.1 directs the entry into the Required Actions and Completion Times associated for the individual component served by the inoperable relay. The instrumentation signals that provide the actuation are governed by LCO 3.3.2, "Engineered Safety Features Actuation System Instrumentation" for safety injection (SI), Containment Spray (Containment Depressurization Actuation (CDA)) and LCO 3.3.5, "Loss of Power (LOP) Emergency Diesel Generator (EDG) Start Instrumentation" for the LOP.

The STRs provide a time delay for the individual component to close its breaker to the associated emergency electrical bus. Each component is sequenced onto the emergency bus by an initiating signal. Required Action K.2.1 provides for the immediate isolation of the component(s) ability to automatically load on an emergency bus with an inoperable STR.

This provides an assurance that the component will not be loaded onto an emergency bus at an incorrect time. Improper loading sequence may cause the emergency bus to become inoperable rendering a component with an inoperable STR incapable of load to the emergency bus prevents a possible overload condition. Required Action K.2.2 provides an alternative option for isolating the component with an inoperable STR from the emergency bus by allowing the associated EDG to be declared inoperable.

North Anna Units 1 and 2 Insert to Page B 3.8-14 Revision 19 North Anna Units 1 and 2 Insert to Page B 3.8-14 Revision 19

ITS 3.8.4 - DC SOURCES - OPERATING INSERT The EDG DC electrical power system consists of the battery, battery charger, and interconnecting cabling to supply the required DC voltage to allow the associated EDG components to perform the required safety function.

For the other unit, control power for breakers and electrical power for solenoid operated valves that are needed to support operation of each required Service Water (SW) pump, Main Control Room (MCR)/Emergency Switchgear Room (ESGR) Emergency Ventilation System (EVS) fan, Auxiliary Building central exhaust fan and Component Cooling Water P 1 (CC) pump. SW, MCR/ESGR EVS, Auxiliary Building central exhaust system and CC are shared systems.

North Anna Units 1 and 2 Insert to Page B 3.8 -51 Revision 19 North Anna Units 1 and 2 Insert to Page B 3.8 - 51 Revision 19

ITS 3.8.4 - DC SOURCES - OPERATING INSERT 1 The OPERABILITY of the EDG DC electrical power system ensures the EDG may perform its required safety function.

INSERT 2 The EDG DC electrical power system consists of the battery, battery charger, and interconnecting cabling to supply the required DC voltage to allow the associated EDG components to perform the required safety function.

INSERT 3 Additionally, the unit's electrical sources must include DC sources from the other unit that

."07 i?3 are required to support the SW, MCR/ ESGR EVS, Auxiliary Building central exhaust system or CC safety functions. Control power for breakers and electrical power for solenoid operated valves are examples of support systems required to be OPERABLE that are needed for the operation of each required SW pump, MCR/ ESGR EVS fan, Auxiliary Building central exhaust fan and CC pump. SW, MCR/ESGR EVS, Auxiliary Building central 1I11 exhaust system and CC are shared systems.

North Anna Units 1 and 2 Insert to PageB 3.8-52 Revision 19 North Anna Units 1 and 2 Insert to Page B 3.8 - 52 Revision 19

ITS 3.8.4 - DC SOURCES - OPERATING INSERT C.1 Condition C represents the loss of the ability of the EDG DC system (e.g., inoperable battery charger or inoperable battery) to supply necessary power to the associated EDG. In this condition, the associated EDG is immediately declared inoperable and the associated Conditions or Required Actions of LCO 3.8.1 are followed.

D.1 Condition D represents the loss of one or more required LCO 3.8.4.c DC electrical power subsystem(s) needed to support the operation of required shared components on the other unit. SW, MCR/ESGR EVS, Auxiliary Building central exhaust system and CC are shared I )lq systems. In this condition, the associated required shared components are declared inoperable immediately. The associated Conditions or Required Actions of LCO 3.7.8, "Service Water System," LCO 3.7.10, "MCR/ESGR Emergency Ventilation Systems," LCO 3.7.12, "Emergency Core Cooling System Pump Room Exhaust Air Cleanup System," and 1/711 LCO 3.7.19, "Component Cooling Water (CC) System," are followed.

North Anna Units 1 and 2 Insert to Page B 3.8 - 54 Revision 19 Insert to Page B 3.8 - 54 Revision 19 North Anna Units I and 2

ITS 3.8.9 DISTRIBUTION SYSTEMS - OPERATING INSERT 1 Unit 1 has a normal offsite source and an alternate offsite source. Transfer to the alternate pr offsite source is a manual operation. Unit 2 has a normal offsite source, and no alternate source. In the event of a loss of offsite power, the EDGs for the affected buses will start and load. The EDGs for Unit 1 will continue to run until a) the safety bus is transferred to the alternate offsite source, or b) the normal off site source is restored. The Unit 2 EDGs will continue to run until the normal off site source is restored.

INSERT 2 For the other unit, one AC and DC bus on that unit is needed to support operation of each required Service Water (SW) pump, Main Control Room (MCR)/Emergency Switchgear Room (ESGR) Emergency Ventilation System (EVS) fan, Auxiliary Building central exhaust fan and Component Cooling Water (CC) pump. SW, MCR/ESGR EVS, Auxiliary Building 1

central exhaust system and CC are shared systems.

North Anna Units 1 and 2 Insert to Page 3.8-79 Revision 19 North Anna Units 1 and 2 Insert to Page 3.8-79 Revision 19

ITS 3.8.9 DISTRIBUTION SYSTEMS - OPERATING INSERT 1 D.1 With one or more required LCO 3.8.9.b AC electrical power distribution subsystem(s) inoperable, the shared component(s) on the other unit is not capable of operating. In this condition, the associated shared component is declared inoperable immediately. SW, MCR/ESGR EVS, Auxiliary Building central exhaust system and CC are shared systems.

I '1'1 The associated Conditions or Required Actions of LCO 3.7.8, "Service Water System," LCO 3.7.10, "MCR/ESGR Emergency Ventilation System," LCO 3.7.12, "Emergency Core Cooling System Pump Room Exhaust Air Cleanup System," and LCO 3.7.19, "Component n

Cooling Water (CC) System," are followed.

E.. 1 With one or more required LCO 3.8.9.b DC electrical power distribution subsystem(s) inoperable, the shared component(s) on the other unit is not capable of operating. In this condition, the associated shared component is declared inoperable immediately. SW, MCR/ESGR EVS, Auxiliary Building central exhaust system and CC are shared systems.

ell The associated Conditions or Required Actions of LCO 3.7.8, LCO 3.7.10, LCO 3.7.12 and LCO 3.7.19 are followed.

INSERT 2 Condition G corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one inoperable LCO 3.8.9.a electrical power distribution subsystem results in the loss of a required function, the unit is in a condition outside the accident analysis. Therefore, no additional time is justified R3 for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

North Anna Units 1 and 2 Insert to Page 3.8-86 Revision 19 North Anna Units I and 2 Insert to Page 3.8-86 Revision 19

DISCUSSION OF CHANGES ITS 3.8.1 - AC SOURCES - OPERATING ADMINISTRATIVE CHANGES A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-143 1, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two service water loops (shared with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service water pumps (excluding auxiliary service water pumps) with their associated normal and emergency power supplies, and an OPERABLE flow path." Each unit's service water system requirements consist of the above requirements for either unit operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.1, Component Cooling Water System

- Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) / Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System. This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the MCR/ESGR and Auxiliary Building exhaust ventilation systems are components that may be required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS LCO 3.8.1 Action J states, "Two required LCO 3.8.1.c EDGs inoperable, declare shared components inoperable immediately." This changes the CTS by specifically stating the requirement in the ITS Action J.

The purpose of the proposed change is to structure the existing electrical requirements for the shared components in the ITS by placing electrical requirements in ITS section 3.8. This change is acceptable because the AC sources requirements for the SW, CC,

[R1 MCR/ESGR Emergency Habitability System, and ECCS Pump Room Exhaust Cleanup System functions are contained in the electrical requirement section of the unit's Technical Specifications. The additional requirements of the fans in the ventilation specifications are addressed by more restrictive discussion of changes to the CTS requirements. The additional electrical requirements are classified as administrative because of the systems may require electrical power from both units in order to satisfy the individual safety function. This change is designated as administrative because it does not result in a technical change to the CTS.

A.3 CTS 3.8.1.1 Actions b.1 and b.2 provide an allowance to have an EDG inoperable for up to 14 days. These Actions require the OPERABILITY of the alternate AC (AAC)

North Anna Units 1 and 2 Page 1 Revision 19

DISCUSSION OF CHANGES ITS 3.8.1 - AC SOURCES - OPERATING A.7 CTS 3.8.1.1 Action e applies when two EDGs are inoperable and requires one EDG to be restored to OPERABLE status within two hours. This requirement also states, "demonstrate the OPERABILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter."

In addition the CTS requires, "Following restoration of one EDG, follow Action Statement

b. with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable EDG." ITS Actions B and I are constructed to track the inoperability of one and two EDGs. ITS Action B requires that each inoperable EDG be tracked and ITS Action I applies when both EDGs are inoperable. Therefore, ITS Action B must be entered if one or two EDGs are inoperable and requires the performance of SR 3.8.1.1 within one hour and every eight hours thereafter. This maintains the CTS requirement to demonstrate the OPERABILITY of two offsite AC circuits within an hour and every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter when one or two EDGs are inoperable.

This change is acceptable because the technical requirements remain the same. The ITS requires multiple condition entry. Therefore, ITS Actions B and I would both be entered if two EDGs were inoperable and Action B would be followed until both EDGs were restored to OPERABLE status. This has the same effect as the CTS requirements.

Therefore, the deletion of the wording in CTS 3.8.1.1 Action e does not modify the technical requirements of the CTS and the unit would be required to be in MODE 5 (COLD SHUTDOWN) within 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months after reducing to MODE 3 (HOT STANDBY).

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

A.8 CTS LCO 3.8.1.1 does not contain an Action for more than two sources of either offsite circuits or EDGs inoperable. Having more than two sources inoperable requires entering CTS LCO 3.0.3. ITS 3.8.1, Action M, requires entering LCO 3.0.3 immediately if three or more AC sources are inoperable.

The change is acceptable because the CTS Actions for more than two sources inoperable are the same as the ITS Actions. This change is designated as administrative because it does not result in a technical change to the CTS.

A.9 CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two service water loops (shared with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service water pumps (excluding auxiliary service water pumps) with their associated normal and emergency power supplies, and an OPERABLE flow path." Each unit's service water system specification applies when either unit is operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4.

ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) /

Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System.

Revision 19 North Anna Units 1 and 2 Page 4

DISCUSSION OF CHANGES ITS 3.8.1 - AC SOURCES - OPERATING This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the ventilation systems are components that may be required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS LCO 3.8.1, "AC Sources," part c states, "One qualified circuit between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System and one EDG capable of supplying the onsite Class 1E AC power distribution subsystem on the other unit for each required shared component; and." This change maintains the CTS requirements for AC sources in the ITS format.

The purpose of the proposed change is to structure the existing electrical requirements for the shared components in the ITS by placing electrical requirements in ITS Section 3.8. This change is acceptable because the AC sources requirements for the SW, CC, J

MCR/ESGR Emergency Habitability System, and ECCS Pump Room Exhaust Cleanup System functions are moved to the electrical requirement section of the unit's Technical Specifications. The additional requirements of the fans in the ventilation specifications are addressed by more restrictive discussion of changes to the CTS requirements. The movement of the electrical requirements is classified as administrative because of the systems may require electrical power from both units in order to satisfy the individual safety function. This change is designated as administrative because it does not result in a technical change to the CTS.

A.10. CTS SR 4.8.1.1.2.a.4 states "Verifying the EDG can start ** and voltage and frequency at 4160 +/- 420 volts and 60 +/- 0.5 Hz." The note ** states, "This test shall be conducted in accordance with the manufacturer's recommendations regarding engine prelube and warmup procedures, and as applicable regarding loading recommendations." ITS SR 3.8.1.2 states, "Verify each EDG starts from standby conditions and achieves steady state voltage of > 3740 V to :4580 V, and the frequency from > 59.5 Hz to < 60.5 Hz." Two Notes modify SR 3.8.1.2. Note 1 states, "All EDG starts may be preceded by an engine prelube period and followed by a warm up period prior to loading." Note 2 states, "A modified EDG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When a modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met." This changes the CTS by specifically stating the requirements and allowances in the ITS format.

This change is acceptable because the requirements of the CTS are maintained in the ITS requirements. ITS Note 1 maintains the allowances provided by the CTS note for a prelube and warmup period prior to loading. ITS Note 2 establishes that ITS SR 3.8.1.2 may involve idling and gradual acceleration to synchronous speed and SR 3.8.1.2 may be credited when performing SR 3.8.1.7. This is acceptable because the CTS note allows loading in accordance with loading recommendations and SR 3.8.1.7 meets or exceeds the technical requirements of SR 3.8.1.2. This change is designated as administrative because it does not result in a technical change to the CTS.

North Anna Units 1 and 2 Page 5 Revision 19

DISCUSSION OF CHANGES ITS 3.8.1 - AC SOURCES - OPERATING Surveillance is only applicable to Unit 1." This changes the CTS by specifically stating 0,,

that the SR is only to Unit 1.

This change is acceptable because SR 4.8.1.1.1.b has been deleted for Unit 2. The R3 purpose of the note is to limit the SR to be required for Unit 1. This change is designated as administrative because the addition of the Note does not result in a technical change to the Unit 1 CTS.

A.18 CTS Surveillance Requirement 4.8.1.1.2.d.5.c requires the verification that all EDG trips, except engine overspeed, generator differential and breaker overcurrent are automatically bypassed on an emergency start. The output breaker overcurrent for the EDG is not a trip for the diesel and should not be included in the exception. ITS SR 3.8.1.12 requires the verification of each EDG's automatic trips are bypassed on an actual or simulated automatic start signal except for engine overspeed and generator differential current.

This changes the CTS by eliminating the EDG output breaker overcurrent from the list of EDG trips.

This change is acceptable because the output breaker overcurrent does not provide a trip of the EDG. With the deletion of the output breaker overcurrent, no technical requirement is added or deleted with the conversion of the CTS requirements to the ITS requirements. The output breaker overcurrent should not have been included in the CTS requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

A.19 CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two service water loops (shared with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service water pumps (excluding auxiliary service water pumps) with their associated normal and emergency power supplies, and an OPERABLE flow path." Each unit's service water system specification applies when either unit is operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4.

ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) /

Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System.

This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the ventilation systems are components that may be required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS 3.8.1Action F states if the required offsite circuit and EDG on the other unit that support a required shared components become inoperable, the supported shared components will be declared inoperable immediately. The differences between the requirements for the shared systems of the CTS and the ITS are addressed in ITS LCOs 3.7.8, 3.7.10, 3.7.12, and 3.7.19. This change maintains the CTS requirements in the ITS format.

North Anna Units 1 and 2 Page 8 Revision 19 Revision 19 North Anna Units 1 and 2 Page 8

DISCUSSION OF CHANGES ITS 3.8.1 - AC SOURCES - OPERATING actual SI signal ITS SR 3.8.1.11 does not result in any change in emergency bus voltage or frequency. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.10 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria) CTS Surveillance Requirements 4.8.1.1.1 and 4.8.1.1.2 contain requirements to perform various testing "during shutdown." ITS SRs 3.8.1.8, 3.8.1.12, and 3.8.1.13 add a Note that restricts performance of the SRs in MODES 1 and 2. The Note is modified with an allowance that the SR may be performed for the purpose of re-establishing OPERABILITY for inoperable equipment. This changes the CTS by allowing the specified surveillances to be performed in a MODE that is not currently allowed.

The purpose of the surveillance Notes is to allow the requirement to be performed without requiring the unit to be shutdown unnecessarily. This change is acceptable

3. &

because it has been determined that the relaxed Surveillance Requirement acceptance tq 3 criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This change modifies when Surveillance Requirements may be performed. The performances of these SRs with the unit operating at full power will not significantly perturbate the electrical system. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.1 1 (Category 4 - Relaxation of Required Action) CTS LCO 3.7.4.1, Service Water System Operating, states, "Two service water loops (shared with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service water pumps (excluding auxiliary service water pumps) with their associated normal and emergency power supplies, and an OPERABLE flow path....." Each unit's service water system requirements consist of the above requirements for either unit operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE.

/t1 This requirement must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) / Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System.

This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the ventilation systems are components that may be K>19 required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS LCO 3.8.1 Actions A, B, and C provide for an evaluation of all safety functions powered by this unit's AC sources and provide 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for an inoperable offsite circuit and up to 14 days for an inoperable EDG. ITS 3.8.1 Action D for one or more offsite circuit(s), and Actions E and F for an inoperable EDG on the other unit that is needed to support a shared components. This changes the CTS by allowing a shared components to be considered OPERABLE for North Anna Units 1 and 2 Page 21 Revision 19 Revision 19 Page 21 North Anna Units 1 and 2

DISCUSSION OF CHANGES ITS 3.8.9 DISTRIBUTION SYSTEMS - OPERATING ADMINISTRATIVE CHANGES A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 1, "Standard Technical Specifications Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 Not used.

A.3 ITS Action G states that with two trains of inoperable distribution subsystems that result in a loss of safety function, enter LCO 3.0.3 immediately. The CTS does not include this specific requirement. This changes the CTS by specifically requiring entry into LCO 3.0.3 when a loss of function occurs.

This change is acceptable because CTS LCO 3.0.3 would be entered when a LCO is not met and there are no Conditions or Required Actions stated. The loss of more than one bus continues to require the entry into LCO 3.0.3 in the CTS and ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

A.4 CTS LCO 3.8.2.1 states that the following AC electrical busses shall be OPERABLE and energized with the tie breakers open between redundant busses. These buses include H and J trains of AC 4160 and 480 volts subsystems. This requirement also includes that each of the four 120-volt AC vital buses is energized from its associated inverter that is powered from an associated 125-volt DC bus. CTS LCO 3.8.2.3 requires the following DC bus trains to be energized and OPERABLE with tie breakers between bus trains open. The trains consists of two 125-volt DC buses, two batteries, and a charger. The makeup of the 4160, 480, and 120 volt AC buses and the DC buses is addressed by DOC LA.2. The requirement that all buses are energized is addressed by DOC LA.1. ITS LCO 3.8.9 requires that the H and J Trains of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE. This changes the CTS by combining the requirements for AC and DC distribution systems into one specification.

This change is acceptable because the technical requirements of the CTS are maintained in the ITS requirements. The CTS and the ITS require the various AC and DC subsystems to be OPERABLE. This change is designated as administrative because it does not result in a technical change to the CTS.

A.5 CTS LCO 3.7.4.1 requires the normal and emergency power supplies to be OPERABLE for the required Service Water pumps. The Control Room ventilation Revision 0 North Anna Units I and 2 Page 1

DISCUSSION OF CHANGES ITS 3.8.9 DISTRIBUTION SYSTEMS - OPERATING fans, the Auxiliary Building central exhaust fans, and the Component Cooling Water (CC) pumps may require electrical power from the other unit for the pumps and fans I to be considered OPERABLE. ITS LCO 3.8.9, Actions, and Surveillance Requirements are modified to include the electrical distribution systems on the other unit that are required to support shared components that are powered for the other unit. This change maintains the CTS requirements in the ITS format.

The change is acceptable because these requirements ensure the electrical distribution systems that are needed to support shared components on the other unit, needed for this unit, are maintained OPERABLE. This is the intent of the CTS requirements in LCO 3.7.4.1 for the required shared components are to ensure all electrical system necessary to power these components. This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M. 1 CTS 3.8.2.1 Action a. states that with one of the required A.C. emergency busses not fully energized, re-energize the bus within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Action b. states within one A.C.

Vital Bus not energized, re-energize the A. C. Vital bus within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . CTS 3.8.2.3 Action a states with one 125 VDC bus inoperable, restore the inoperable bus to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.8.9, Action A, states that with one AC subsystem inoperable, restore the subsystem to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. Action B states that with one AC vital bus inoperable, restore the AC bus to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. Action C states that with one DC vital bus inoperable restore the DC bus to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO. This changes the CTS by placing a limit of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months for failing to meet the LCO when the CTS does not specify a limit.

This change is acceptable because it provides a reasonable period of time to restore all required subsystems to OPERABLE status, but specifies a finite time the LCO may not be met. This change is designated as more restrictive the ITS imposes a 16-hour Completion Time which the CTS does not impose.

M.2 CTS 4.8.2.1 states the specified A.C. busses shall be determined OPERABLE at least once per 7 days by verifying indicated power availability. CTS 4.8.2.3.1 states that each D.C. bus train shall be demonstrated OPERABLE at least once per 7 days by verifying indicated power availability. ITS SR 3.8.9.1 requires the verification of the correct voltage to required AC, DC, and AC vital buses electrical power distribution subsystems every 7 days. This changes the CTS by requiring the verification of the correct voltages to the required AC, DC, and AC vital buses electrical power distribution subsystems, where the CTS only requires verification of indicated power.

The purpose of this change is to ensure proper voltage is supplied to the required AC, DC, and AC vital buses electrical power distribution subsystems. This change is Revision 19 North Anna Units 1 and 2 Page 2

REVISION OF DOC TABLES FOR SE

Table A - Administrative Changes ITS Section 3.7 - Plant Systems DOC No.

Description of Change ITS Requirement CTS Requirement 3.7.17 A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

3.7.18 A. 1 In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

3.7.19 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

3.7.19 A.2 CTS 3.7.3.1 states that the CC loops are shared by the units. The Applicability applies when LCO 3.7.19 3.7.3.1, Actions a, either unit is in MODES 1, 2, 3, or 4. Actions a, b, and c contain requirements on both units.

b, and c ITS 3.7.19 is written to apply to a single unit. The change to the LCO is described in DOC LA.1.

The change to the Applicability and the Actions are administrative changes necessary to be consistent with the change to the LCO. This presentation is also consistent with the presentation used in ITS LCO 3.7.8, Service Water System, which is a similar shared system.

This change is acceptable because both units are required to follow the Technical Specifications and CC is a shared system. If a required CC subsystem is inoperable, both units are affected. The CC applies to each unit that is in the Applicability, so if either unit is in MODE 1, 2, 3, or 4, the CC System is required to be OPERABLE. If one or more CC subsystems are inoperable, ACTIONS must be entered on both units if both are in the Applicable MODES. Therefore, eliminating the cross-unit references is an administrative change. This change is designated as administrative because it does not result in technical changes to the CTS.

A-3.7 North Anna Power Station Page 12 of 13

Table A - Administrative Changes ITS Section 3.7 - Plant Systems A - 3.7 North Anna Power Station DOC No.

Description of Change ITS Requirement CTS Requirement 3.7.19 A.3 CTS 3.7.3.1 includes footnote "**" which allows a temporary exception to the CC LCO for None 3.7.3.1, footnote service water system upgrades. ITS 3.7.19 does not contain that temporary exception.

This change is acceptable because the temporary exception was only allowed to be used two times (once per SW loop). The temporary exception has been used and is no longer valid. This change is designated as administrative because it does not result in technical changes to the CTS.

3.7.19 A.4 CTS 3.7.3.1 Actions refer to CTS MODE names, "Hot Standby," "Hot Shutdown," and "Cold ACTIONS A, B, C, 3.7.3.1, Actions a, Shutdown." ITS 3.7.19 uses the corresponding ITS MODE numbers, "MODE 3," "MODE 4,"

and D b, and c and "MODE 5." This changes the CTS by utilizing MODE numbers instead of MODE names.

Any technical changes associated with the differences in CTS MODES and ITS MODES are discussed in Chapter 1.0.

This change is acceptable because the ITS uses MODE numbers instead of MODE names. Any technical changes associated with the differences in CTS MODES and ITS MODES are discussed in Chapter 1.0. This change is designated as administrative because it does not result in technical changes to the CTS.

Page 13 of 13

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change DOC No.

Requirement Description of Relocated Requirements Location Process Category 3.7.18 None N/A N/A N/A N/A N/A 3.7.19 LA. 1 3.7.3.1 CTS LCO 3.7.3.1 states that three CC subsystems, shared with the Bases ITS 5.5.13, 1

other unit, shall be OPERABLE and contains a description of what Technical constitutes an OPERABLE subsystem. Footnote "*" provides Specifications further details on what constitutes an operable subsystem. ITS Bases Control 3.7.19 requires three CC subsystems to be OPERABLE. This Program changes CTS by moving the details of what constitutes an OPERABLE subsystem, including that the subsystems are shared between the units, to the Bases.

CTS 3.7.1.6 3.7.1.6 CTS 3.7.1.6 states that the structural integrity of the steam turbine Technical 10 CFR 50.59 R

R. 1 assembly shall be maintained in MODES 1 and 2. The steam Requirements turbine assembly is used to provide the motive force for the main Manual electrical generator. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.7.1.7 3.7.1.7 CTS 3.7.1.7 states that at least one turbine overspeed protection Technical 10 CFR 50.59 R

R. 1 system shall be OPERABLE in MODES 1, 2, and 3. The turbine Requirements overspeed protection system is used to prevent a turbine overspeed Manual condition that could result in turbine damage. The turbine overspeed protection system serves no accident mitigation function in any MODE. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Change Category:

1 - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 1

3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station ell R - 3.7 Page 8 of 13

Table R - Relocated Specifications and Removed Details ITS Section 3.7 - Plant Systems CTS Change Control Change DOC No.

Requirement Description of Relocated Requirements Location Process Category CTS 3.7.2.1 3.7.2.1 CTS 3.7.2.1 states that the temperature of both the primary and Technical 10 CFR 50.59 R

R. 1 secondary coolants in the steam generators shall be greater than Requirements 70' when the pressure of either coolant in the steam generator is Manual greater than 200 psig at all times. The Steam Generator Pressure/Temperature Limitation serves no accident mitigation function in any MODE. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

CTS 3.7.3.1 3.7.3.1 Not used.

_1 CTS 3.7.3.2 3.7.3.2 CTS 3.7.3.2 states that two component cooling water system (CC)

Technical 10 CFR 50.59 R

R. 1 loops shall be OPERABLE. It is applicable when both units are in Requirements MODES 5 or 6. The primary function of the CC System is to Manual provide cooling water to the Residual Heat Removal (RHR) heat exchangers, but does not warrant its own LCO. If insufficient CC is available for RHR, RHR is declared inoperable and the Conditions and Actions for CC in CTS are the same as those for RHR. Unlike other Westinghouse plants, RHR does not share components with the Emergency Core Cooling System (ECCS),

and thus does not play a role in DBA mitigation in MODES 1, 2, 3, and 4. Other plants use CC for DBA mitigation functions other than ECCS in MODES 1, 2, 3, and 4, but the CC system at NAPS does not. This makes the CC System at NAPS different from the CC System described in the ISTS, and retaining the CC requirement for MODES 5 and 6 for supporting RHR or any other components not assumed in DBA analysis is inappropriate. This LCO does not meet the criteria for retention in the ITS; therefore, it will be retained in the Technical Requirements Manual.

Change Category:

I - Removing Details of System Design and System Description, Including Design Limits 2 - Removing Descriptions of System Operation 3 - Removing Procedural Details for Meeting TS Requirements and Related Reporting 4 - Removing Performance Requirements for Indication-Only Instrumentation and Alarms 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report North Anna Power Station R - 3.7 Page 9 of 13

Table L - Less Restrictive Changes ITS Section 3.7 - Plant Systems Change Category:

I - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements Note 1 - Certain Less Restrictive changes for Section 3.7 did not fall into the categories used for the other Section. A specific Determination of No Significant Hazards Consideration was written for each non-categorized Less Restrictive Change in Section 3.7.

North Anna Power Station Page 18 of 18 L - 3.7 DOC No.

Description of Change ITS Requirement CTS Requirement Change Type 3.7.19 L. I CTS 4.7.3..b requires each component cooling water pump to be tested in None 4.7.3.1.b 5

accordance with Specification 4.0.5. ITS 3.7.19 does not contain this Surveillance.

This changes the CTS by deleting a Surveillance Requirement.

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No.

Description of Change ITS Requirement CTS Requirement 3.8.1 A.2 CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two service water loops (shared 3.8.1, Required CTS LCO 3.7.4.1 with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service Action J water pumps (excluding auxiliary service water pumps) with their associated normal and emergency power supplies, and an OPERABLE flow path." Each unit's service water system requirements consist of the above requirements for either unit operating in MODES 1, 2, 3, or 4.

CTS LCO 3.7.3.1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) / Emergency Switchgear Room (ESGR)

Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System. This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the MCRIESGR and Auxiliary Building exhaust ventilation systems are components that may be required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS LCO 3.8.1 Action J states, "Two required LCO 3.8..c EDGs inoperable, declare shared components inoperable immediately." This changes the CTS by specifically stating the requirement in the ITS Action J.

The purpose of the proposed change is to structure the existing electrical requirements for the shared components in the ITS by placing electrical requirements in ITS section 3.8. This change is acceptable because the AC sources requirements for the SW, CC, MCR/ESGR Emergency Habitability System, and ECCS Pump Room Exhaust Cleanup System functions are contained in the electrical requirement section of the unit's Technical Specifications. The additional requirements of the fans in the ventilation specifications are addressed by more restrictive discussion of changes to the CTS requirements. The additional electrical requirements are classified as administrative because of the systems may require electrical power from both units in order to satisfy the individual safety function. This change is designated as administrative because it does not result in a technical change to the CTS.

North Anna Power Station A -3.8 Page 2 of 24

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No.

Description of Change ITS Requirement CTS Requirement 3.8.1 A.9 CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two service water loops (shared LCO 3.7.10, LCO 3.7.4.1 with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service LCO 3.7.12, water pumps (excluding auxiliary service water pumps) with their associated normal and LCO 3.7.19 emergency power supplies, and an OPERABLE flow path." Each unit's service water system LCO 3.8.1.c specification applies when either unit is operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) / Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System. This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the ventilation systems are components that may be required by either or both units.

Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS LCO 3.8.1, "AC Sources," part c states, "One qualified circuit between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System and one EDG capable of supplying the onsite Class 1E AC power distribution subsystem on the other unit for each required shared component; and." This change maintains the CTS requirements for AC sources in the ITS format.

The purpose of the proposed change is to structure the existing electrical requirements for the shared components in the ITS by placing electrical requirements in ITS Section 3.8. This change is acceptable because the AC sources requirements for the SW, CC, MCR/ESGR Emergency Habitability System, and ECCS Pump Room Exhaust Cleanup System functions are moved to the electrical requirement section of the unit's Technical Specifications. The additional requirements of the fans in the ventilation specifications are addressed by more restrictive discussion of changes to the CTS requirements. The movement of the electrical requirements is classified as administrative because of the systems may require electrical power from both units in order to satisfy the individual safety function. This change is designated as administrative because it does not result in a technical change to the CTS.

A-3.8 Page 7 of 24 North Anna Power Station

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems A-3.8 North Anna Power Station DOC No.

Description of Change ITS Requirement CTS Requirement 3.8.1 A. 19 CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two service water loops (shared LCO 3.7.10, LCO 3.7.4.1 with the other unit) shall be OPERABLE with each loop consisting of two OPERABLE service LCO 3.7.12 water pumps (excluding auxiliary service water pumps) with their associated normal and LCO 3.7.19 emergency power supplies, and an OPERABLE flow path." Each unit's service water system 3.8. 1, Action F specification applies when either unit is operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.1, Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) / Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System. This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the ventilation systems are components that may be required by either or both units.

Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS 3.8.1 Action F states if the required offsite circuit and EDG on the other unit that support a required shared components become inoperable, the supported shared components will be declared inoperable immediately. The differences between the requirements for the shared systems of the CTS and the ITS are addressed in ITS LCOs 3.7.8, 3.7.10, 3.7.12, and 3.7.19.

This change maintains the CTS requirements in the ITS format.

This change is acceptable because the technical requirements of the CTS are maintained in the ITS. If a shared components is required to be OPERABLE for this unit and the pump or fan is powered from the other unit's electrical system, the loss of the normal and emergency AC source would required the pump or fan to be declared inoperable and appropriate Action for the affected system to be entered. This change is designated as administrative because it does not result in a technical change to the CTS.

Page 12 of 24

Table A - Administrative Changes ITS Section 3.8 - Electrical Power Systems DOC No.

Description of Change ITS Requirement CTS Requirement 3.8.9 A.5 CTS LCO 3.7.4.1 requires the normal and emergency power supplies to be OPERABLE for the LCO 3.8.9 LCO 3.7.4.1 required Service Water pumps. The Control Room ventilation fans, the Auxiliary Building central exhaust fans, and the Component Cooling Water (CC) pumps may require electrical power from the other unit for the pumps and fans to be considered OPERABLE. ITS LCO 3.8.9, Actions, and Surveillance Requirements are modified to include the electrical distribution systems on the other unit that are required to support shared components that are powered for the other unit. This change maintains the CTS requirements in the ITS format.

The change is acceptable because these requirements ensure the electrical distribution systems that are needed to support shared components on the other unit, needed for this unit, are maintained OPERABLE. This is the intent of the CTS requirements in LCO 3.7.4.1 for the required shared components are to ensure all electrical system necessary to power these components. This change is designated as administrative because it does not result in a technical change to the CTS.

3.8.10 A. I In the conversion of the North Anna Current Technical Specifications (CTS) to the plant specific Various Various Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG 1431, Rev. 1, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

3.8.10 A.2 ITS 3.8.10 Required Action A.2.5 states, "Declare associated required residual heat removal 3.8.10, Required None subsystem(s) inoperable and not in operation." This is required with a Completion Time of Action A.2.5 "Immediately." CTS 3.8.2.2 does not specifically state this requirement. This changes the CTS by specifically requiring the RHR subsystem(s) to be declared inoperable with a loss of the associated electrical bus.

This change is acceptable because the RHR subsystem(s) would be declared inoperable under the CTS requirements. This addition does not change the technical requirements of the CTS but acts as a reminder to enter the Action for the RHR subsystem(s). This change is designated as administrative because it does not result in a technical change to the CTS.

A-3.8 North Anna Power Station Page 24 of 24

Table L - Less Restrictive Changes ITS Section 3.8 - Electrical Power Systems DOC No.

Description of Change ITS Requirement CTS Requirement Change Type 3.8.1 L. 1I CTS LCO 3.7.4.1, Service Water System - Operating, states, "Two service water LCO 3.7.10, 3.7.4.1 4

loops (shared with the other unit) shall be OPERABLE with each loop consisting of LCO 3.7.12, two OPERABLE service water pumps (excluding auxiliary service water pumps)

LCO 3.7.19, with their associated normal and emergency power supplies, and an OPERABLE LCO 3.8.1 Actions flow path.... " Each unit's service water system requirements consist of the above A, B, C, D, E, and requirements for either unit operating in MODES 1, 2, 3, or 4. CTS LCO 3.7.3.1, F

Component Cooling Water System - Operating, requires three component cooling water subsystems (shared with the other unit) shall be OPERABLE. This requirement must be met with either unit is in MODES 1, 2, 3, or 4. ITS LCO 3.7.10 specifies the requirements for the Main Control Room (MCR) / Emergency Switchgear Room (ESGR) Habitability System. This system requires the MCR and ESGR fans on both units to be OPERABLE in MODES 1, 2, 3, and 4 and during the movement of recently irradiated fuel assemblies. ITS LCO 3.7.12 requires the fans from the Auxiliary Building central exhaust system to be OPERABLE to support the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System. This could require a fan powered from the other unit to be required for this unit. The SW and CC pumps and the fans from the ventilation systems are components that may be required by either or both units. Therefore, these pumps and fans are classified as "shared components," for the electrical power requirements. ITS LCO 3.8.1 Actions A, B, and C provide for an evaluation of all safety functions powered by this unit's AC sources and provide 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for an inoperable offsite circuit and up to 14 days for an inoperable EDG. ITS 3.8.1 Action D for one or more offsite circuit(s), and Actions E and F for an inoperable EDG on the other unit that is needed to support a shared components. This changes the CTS by allowing a shared components to be considered OPERABLE for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with a required offsite circuit(s) inoperable and up to 14 days for an inoperable EDG on the other unit.

Change Category:

1 - Relaxation of LCO Requirements 2 - Relaxation of Applicability 3 - Relaxation of Completion Time 4 - Relaxation of Required Action 5 - Deletion of Surveillance Requirement 6 - Relaxation Of Surveillance Requirement Acceptance Criteria 7 - Relaxation Of Surveillance Frequency 8 - Deletion of Reporting Requirements L-3.8 Page 5 of 5 North Anna Power Station

v t e Letter Sequence Request
TAC:MB1439, (Open) TAC:MB1440, (Open)
Initiation Request, Request, Request, Request Acceptance... Administration Questions Answers Results Approval... Other:
MONTHYEAR2002-03-22 [Table View]

ML020870707

Text

Subject:

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