ML051390483

RAI, Technical Specification Changes, May 19, 2005

ML051390483
Person / Time
Site:	North Anna
Issue date:	05/19/2005
From:	Stephen Monarque NRC/NRR/DLPM/LPD2
To:	Christian D Virginia Electric & Power Co (VEPCO)
Monarque S, NRR/DLPM, 415-1544
References
TAC MC6301, TAC MC6302
Download: ML051390483 (4)

Text

May 19, 2005 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED TECHNICAL SPECIFICATION CHANGES FOR REVISED FREQUENCY FOR TADOT OF P-4 INTERLOCK (TAC NOS. MC6301 AND MC6302)

Dear Mr. Christian:

By letter dated March 1, 2005, Virginia Electric and Power Company (VEPCO) submitted a license amendment request to revise the frequency for performing the Trip Actuating Device Operational Test for the P-4 Interlock Function and add Mode 4 to Technical Specification Table 3.3.2-1. Based on its review of the March 1, 2005 submittal, the NRC staff has determined that additional information is required to complete its review.

The NRC staffs questions are provided in the Enclosure. In its March 1, 2005 submittal, VEPCO requested approval of this license amendment by October 1, 2005, to support the fall 2005 refueling outage. As such, in order to support VEPCOs requested date, the NRC staff requests a response to this request for additional information within 30 days of the date of this letter.

Sincerely,

/RA/

Stephen R. Monarque, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosure:

As stated

ML051390483 NRR-088 OFFICE PDII-1/PM PDII-2/LA PDII-1/SC NAME SMonarque EDunnington EMarinos DATE 05/18/2005 05/18/2005 05/19/2005 REQUEST FOR ADDITIONAL INFORMATION PROPOSED REVISION OF FREQUENCY FOR TADOT OF P-4 INTERLOCK NORTH ANNA POWER STATION, UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

1. The P-4 interlock is enabled when a reactor trip breaker (RTB) and its associated bypass breaker are open. Once the P-4 interlock is enabled, automatic safety injection (SI) initiation is blocked after a time delay. This function allows operators to take manual control of SI systems after the initial phase of injection is complete. Once SI is blocked, automatic actuation of SI cannot occur until the RTBs have been manually closed. The RTB position switches provide input to the P-4 interlock.

NUREG-1431, Rev. 3, Standard Technical Specifications Westinghouse Plants, requires that the surveillance frequency for P-4 interlock is once per RTB cycle, every 62 days on a staggered test basis. This license amendment request (LAR) proposes to change the surveillance frequency for P-4 interlock to once every refueling cycle, every 18 months. In order for the NRC staff to approve this type of surveillance frequency change, the licensee should provide justification to demonstrate that the proposed TS change is based on either hardship (such as challenges to the protection system or increased radiation exposure to plant personnel) or on a risk-informed basis.

2. NUREG-1431, Revision 3 specifies for P-4 interlock that the applicable modes are 1, 2, and 3. This LAR proposes to add Mode 4 for this function. Additional analysis is required to support the proposed change.

3. The March 1, 2005, submittal cited that the proposed changes are consistent with the intent of the Westinghouse Owners Group Technical Specification Task Force Process TSTF-444, Rev. 1, ESFAS Interlocks P-4, P-11, & P-12 LCO Actions and Surveillance Requirements Revisions. Since TSTF-444 has not been approved by the NRC staff, the P-4 interlock-related information contained in TSTF-444 should be submitted with this LAR.

4. The March 1, 2005, submittal cited precedents from five other plants (Wolf Creek, Byron, Braidwood, Comanche Peak, and DC Cook) that maintained their 18-month surveillance test requirement to perform the TADOT of the P-4 interlock function. The NRC staff found that these plants were licensed on that basis; therefore, these precedents cannot be considered as a precedent for a technical specification change as requested in this LAR. However, the operational experience from these plants may be able to be credited as part of a risk-informed basis.

North Anna Power Station, Units 1 & 2 cc:

Mr. C. Lee Lintecum Mr. Jack M. Davis County Administrator Site Vice President Louisa County North Anna Power Station Post Office Box 160 Virginia Electric and Power Company Louisa, Virginia 23093 Post Office Box 402 Mineral, Virginia 23117-0402 Ms. Lillian M. Cuoco, Esq.

Senior Counsel Dr. Robert B. Stroube, MD, MPH Dominion Resources Services, Inc. State Health Commissioner Building 475, 5 th floor Office of the Commissioner Rope Ferry Road Virginia Department of Health Waterford, Connecticut 06385 Post Office Box 2448 Richmond, Virginia 23218 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 Old Dominion Electric Cooperative 4201 Dominion Blvd.

Glen Allen, Virginia 23060 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc.

Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Senior Resident Inspector North Anna Power Station U. S. Nuclear Regulatory Commission 1024 Haley Drive Mineral, Virginia 23117