ML062920444

Safety Evaluation Input for North Anna License Amendment to Adopt TSTF-374 as Part of the Consolidated Line Item Improvement Process (CLIIP)

ML062920444
Person / Time
Site:	North Anna
Issue date:	10/26/2006
From:	Kobetz T NRC/NRR/ADRO/DIRS/ITSB
To:	Marinos E NRC/NRR/ADRO/DORL/LPLC
Hearn, P, NRR/DIRS/ITSB, 301-415-1189
References
TAC MD2107, TAC MD2108
Download: ML062920444 (4)

Text

October 26, 2006 MEMORANDUM TO: Evangelos C. Marinos, Chief Plant Licensing Branch C Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Timothy K. Kobez, Chief /RA/

Technical Specifications Branch Division of Inspection and Regional Support

SUBJECT:

SAFETY EVALUATION INPUT FOR NORTH ANNA LICENSE AMENDMENT TO ADOPT TSTF-374 AS PART OF THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

The Technical Specifications Branch (ITSB) has completed its plant-specific safety evaluation (SE) in response to submittals of Virginia Electric Power Company on May 30, 2006 and June 30, 2006, which requested adoption of TSTF-374. ITSB found the licensees submittal acceptable.

This completes ITSBs work on TAC number(s) MD2107 and MD2108. Based on previous approvals of amendments adopting TSTF-374, ITSB does not recommend routing the final amendment package through the Office of General Counsel.

Sincerely, Timothy J. Kobez, Chief Technical Specifications Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation CONTACT: P. C. Hearn, DIRS/ITSB (301) 415-1189

October 26, 2006 MEMORANDUM TO: Evangelos C. Marinos, Chief Plant Licensing Branch C Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Timothy K. Kobez, Chief /RA/

Technical Specifications Branch Division of Inspection and Regional Support

SUBJECT:

SAFETY EVALUATION INPUT FOR NORTH ANNA LICENSE AMENDMENT TO ADOPT TSTF-374 AS PART OF THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

The Technical Specifications Branch (ITSB) has completed its plant-specific safety evaluation (SE) in response to submittals of Virginia Electric Power Company on May 30, 2006 and June 30, 2006, which requested adoption of TSTF-374. ITSB found the licensees submittal acceptable.

This completes ITSBs work on TAC number(s) MD2107 and MD2108. Based on previous approvals of amendments adopting TSTF-374, ITSB does not recommend routing the final amendment package through the Office of General Counsel.

Sincerely Timothy J. Kobez, Chief Technical Specifications Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation CONTACT: P. C. Hearn, DIRS/ITSB (301) 415-1189 Distribution:

ITSB RF TKobez PCHearn Accession Number: ML062920444 OFFICE DIRS/ITSB DIRS/ITSB/BC NAME PHearn TKobez DATE 10/26/2006 10/26/2006 Official Record Copy

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TECHNICAL SPECIFICATION TASK FORCE CHANGE TRAVELER TSTF-374, Rev.0 REVISION TO STS 5.513 AND ASSOCIATED STS BASES FOR DIESEL FUEL OIL

1.0 INTRODUCTION

By letters dated May 30, 2006 and June 30, 2006, Virginia Electric and Power Company (Dominion) submitted Technical Specification Task Force Change Traveler, TSTF-374, R.0, Revision to STS 5.5.13, Diesel Fuel Oil Testing Program and associated TS Bases for Diesel Fuel Oil. Specifically, the proposed revisions to STS 5.5.13 relocate the specific American Society for Testing and Materials (ASTM) Standard from the Administrative Controls Section of TS to a license-controlled document.

STS 5.5.13 contains the testing requirements for both new fuel oil and stored fuel oil. The Diesel Fuel Oil Testing Program includes sampling and testing requirements and acceptance criteria.

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act (the Act) requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems and components that are required to protect the health and safety of the public. The Commissions regulatory requirements related to the content of the TSs are contained in 10 CFR Section 50.36. That regulation requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings (50.36(c)(1)); (2) Limiting Conditions for Operation (50.36(c)(2)); (3)

Surveillance Requirements (50.36(c)(3)); (4) design features (50.34(c)(4)); and (5) administrative controls (50.36(c)(5)).

In general, there are two classes of changes to TSs: (1) changes needed to reflect modifications to the design basis (TSs are derived from the design basis), and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of TSs over time. This amendment deals with the second class of changes.

In determining the acceptability of revising STS 5.5.13, the staff used the accumulation of generically approved guidance in NUREG-1431, Revision 1, Standard Technical Specifications, Westinghouse Plants, dated April 07, 1995.

Licensees may revise the technical specifications to adopt current improved standard technical specification format and content provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensees current requirement, or (3) the change is less restrictive than the licensees current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0 in the context of specific proposed changes.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the justification for the proposed TSTF as described in the May 30 and June 30 submittals. The detailed evaluation below will support the conclusion that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

3.1 Relocation of the specific American Society for Testing and Materials (ASTM) Standard from the Administrative Controls Section of TS to a license-controlled document The TSTF proposes to relocate the specific American Society for Testing and Materials (ASTM)

Standard for allowable particulate concentration in fuel from the Administrative Controls Section STS 5.5.13 to a license-controlled document, because referencing ASTM Standards in the TS is not required by 10 CFR 50.36. The actual value of allowable particulate concentration in fuel, which is required by 10 CFR 50.36(c), remains in STS 5.5.13.

3.2 Revision to Fuel Color Test in STS 5.5.13.a.3 10 CFR 50.36 requires a DG Fuel Oil Testing Program in the Plant TS. TSTF-374 proposes to provide more objectivity to the fuel oil testing programs fuel color test by replacing a clear and bright appearance with proper color with a clear and bright appearance with proper color or water and sediment content within limits. Since this revision affords additional detail to the appearance test, it is more restrictive than the current STS 5.5.13.a.13. This revision also meets the requirements of 10 CFR 50.36(c) by defining an operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The North Anna TS currently contain this statement.

3.3 Revision to Bases B 3.8.3 Reference On this basis, the NRC staff concludes that the changes proposed by TSTF-374 are acceptable. This proposed revision updates Bases B 3.8.3 to reference the current ASTM Standards. The proposed changed revises the STS Bases for SR 3.8.3.3 to indicate that the API gravity is tested in accordance with ASTM D287-82 and to provide an additional method (ASTM D4294) for sulfur testing.

4.0 CONCLUSION

The changes proposed by TSTF-374 assure the quality of the diesel fuel will be maintained at standards that provide high reliability of diesel availability. The NRC staff concludes that the proposed changes by the licensee satisfy the requirements of 10 CFR 50.36(c). On this basis, the NRC staff concludes that the TSSTF-374 changes proposed by licensee are acceptable.

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and, (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.