ML071410463

Proposed License Amendment Request Addition of LCO 3.0.8 - Inoperability of Snubbers Using the Consolidated Line Item Improvement Process Technical Specification Improvement

ML071410463
Person / Time
Site:	North Anna
Issue date:	05/21/2007
From:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, NRC/NRR/ADRO
References
07-0360
Download: ML071410463 (19)

Text

VIRGINIA ELECTRIC AND POWER COMPANY

RICHMOND, VIRGINIA 2326 1 May 21, 2007 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Serial No.

07-0360 NL&OSlETS RO Docket Nos. 50-3381339 License Nos. NPF-417 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST ADDITION OF LC0 3.0.8 - INOPERABILITY OF SNUBBERS USING THE CONSOLIDATED LINE ITEM INIPROVEMENT PROCESS TECHNICAL SPECIFICATION IMPROVEMENT Pursuant to 10 CFR 50.90, Dominion reques'ts amendments, in the form of changes to the Technical Specifications (TS) to Facility Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively.

The proposed amendment would modify TS requirements for inoperable snubbers by adding LC0 3.0.8.

The change is consistent with NRC-approved Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-372, "Addition of LC0 3.0.8, Inoperability of Snubbers."

The availability of this TS improvement was announced in the Federal Register on May 6, 2005 (70 FR 24126) as part of the cor~solidated line item improvement process (CLIIP). Attachment 1 provides a descriptiom of the proposed change, the requested confirmation of applicability, and plant-specific verifications.

The marked-up and proposed Technical Specifications pages are provided in Attachments 2 and 3, respectively. The associated marked-up Bas'es changes are provided in Attachments 4 for information only and will be implemented in accordance with the Technical Specification Bases Control Program and 10 CFR 50.59.

The proposed changes have been reviewed and approved by the Station Nuclear Safety and Operating Committee.

Dominion requests approval of the license ;amendments by October 31, 2007 with a 90-day implementation period.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the appropriate designated officials of Virginia.

07-0360 Docket Nos. 50-3381339 Page 2 of 4 If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.

Very truly yours, Gerald T. Bischof Vice President - Nuclear Engineering Attachments

1. Discussion of Change

2. Marked-up Technical Specification Changes

3. Proposed Technical Specification Pages'

4. Marked-up Technical Bases Changes Commitments made in this letter:

1.

The 3.0.8 Bases will be implemented when the NRC-approved Technical Specification for LC0 3.0.8 is impleme~nted at North Anna.

07-0360 Docket Nos. 50-3381339 Page 3 of 4 cc:

U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative lnnsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060 Commissioner Bureau of Radiological Health 1500 East Main Street Suite 240 Richmond, Virginia 2321 8 Mr. J. T. Reece NRC Senior Resident Inspector North Anna Power Station Mr. S. P. Lingam NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 1 1555 Rockville Pike Mail Stop 8-HI 2 Rockville, Maryland 20852

07-0360 Docket Nos. 50-3301339 Page 4 of 4 COMMONWEALTH OF VIRGINIA

)

1 COUNTY OF HENRICO

)

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. He has affirmed before me that he 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 his knowledge and belief.

Acknowledged before me this Z/ 5Tday of \\A?-&!

,2007.

My Commission Expires:

2610. u I

(SEAL)

(Serial No. 07-0360)

Discussion of Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

DISCUSSION OF CHANGE

1.0 DESCRIPTION

The proposed amendment would modify technical specifications (TS) requirements for inoperable snubbers by adding LC0 3.0.8.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved lndustryflechnical Specification Task Force (TSTF) STS change TSTF-372, Revision 4.

The availability of this TS improvement was published in the Federal Register on May 4, 2005, as part of the consolidated line item improvement process (CLIIP). The changes include:

Addition of new LC0 3.0.8 to address an inoperable snubber(s) and the associated informational Bases.

Modification of LC0 3.0.1 and its associated Bases to reference the newly added LC0 3.0.8.

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Dominion has reviewed the safety evaluation dated April 27, 2005 as part of the CLIIP.

This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-372. Dominion has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to North Anna Power Station Units 1 and 2 and justify this amendment for the incorporation of the changes to the North Anna TS.

2.2 Optional Changes and Variations Dominion is not proposing any variations or deviations from the TS changes described in the TSTF-372, Revision 4, or the NRC staff's model safety evaluation dated May 4, 2005 (70 FR 23252).

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Dominion has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

Dominion has concluded that the proposed NSHCD presented in the Federal Register

notice is applicable to North Anna and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on May 4, 2005 for this TS improvement, plant-specific verifications were performed as follows:

Dominion has established TS Bases for LC0 3.0.8 which provide guidance and details on how to implement the new requirements. LC0 3.0.8 requires that risk be managed and assessed. The Bases also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LC0 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

The 3.0.8 Bases will be implemented when the approved Technical Specification for LC0 3.0.8 is implemented at North Anna after NRC approval. North Anna Unit 1 and 2 Technical Specifications have a Bases Control Program consistent with Section 5.5 of the STS.

4.0 ENVIRONMENTAL EVALUATION Dominion has reviewed the environmental evaluation included in the model safety evaluation dated April 27, 2005 as part of the CLIIP. Dominion has concluded that the staff's findings presented in that evaluation are applicable to North Anna and the evaluation is hereby incorporated by reference for this application.

Serial No. 07-0360 Docket Nos. 50-338/339 (Serial No. 07-0360)

Marked-up Technical Specification Changes North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

LC0 APPLICABILITY 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LC0 3.0.1 LCOs shall be met during the MODES o r other specified conditions i n the Appl icabi 1 i t exce t as provided i n LC0 3.0.2,+

LC0 3.0.-

LC0 3.0.2 Upon discovery o f a f a i l u r e t o meet an LCO, the Required Actions o f the associated Conditions shall be met, except as provided i n LC0 3.0.5 and LC0 3.0.6.

I f the LC0 i s met o r i s no longer appl icable p r i o r t o expi r a t i o n o f the specified Completion Time(s), completion of the Required Action(s) i s not required unless otherwise stated.

LC0 3.0.3 When an LC0 i s not met and the associated ACTIONS are not met, an associated ACTION i s not provided, o r i f directed by the associated ACTIONS, the u n i t shall be placed i n a MODE o r other specified condition i n which the LC0 i s not applicable. Action shall be i n i t i a t e d within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> t o place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;

b. MODE 4 w i t h i n 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and

c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions t o t h i s Specification are stated i n the individual Specifications.

Where corrective measures are completed t h a t permit operation i n accordance with the LC0 o r ACTIONS, completion o f the actions required by LC0 3.0.3 i s not required.

LC0 3.0.3 i s only applicable i n MODES 1, 2, 3, and 4.

LC0 3.0.4 When an LC0 i s not met, entry i n t o a MODE o r other specified condition i n the A p p l i c a b i l i t y shall only be made:

a. When the associated ACTIONS t o be entered permit continued operation i n the MODE o r other specific condition i n the A p p l i c a b i l i t y f o r an unl imi ted period o f

time, (continued)

North Anna Units 1 and 2 3.0-1 Amendments 231/212

LC0 APPLICABILITY 3.0 3.0 LC0 APPLICABILITY LC0 3.0.7 Test Exception LCOs 3.1.9 and 3.4.19 allow specified Technical Specification (TS) requirements t o be changed t o permit performance o f special tests and operations. Unless otherwise specified, a1 1 other TS requirements remain unchanged. Cornpl i ance with Test Exception LCOs i s optional.

When a Test Exception LC0 i s desired t o be met but i s not met, the ACTIONS o f the Test Exception LC0 shall be met. When a Test Exception LC0 i s not desired t o be met, entry i n t o a MODE o r other specified condition i n the Appl i cabi 1 i t y shall be made i n accordance with the other applicable Specifications.

North Anna Units 1 and 2 Amendments 2311212

LC0 3.0.8 When one or more required snubbers are unable to perform their associated support function@), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a, the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

Serial No. 07-0360 Docket Nos. 50-3381339 (Serial No. 07-0360)

Proposed Technical Specifications Changes North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

LC0 APPLICABILITY 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LC0 3.0.1 LCOs sha l l be met during the MODES or other specified conditions i n the Applicability, except as provided in LC0 3.0.2, LC0 3.0.7, and LC0 3.0.8.

I LC0 3.0.2 Upon d i scovery o f a f a i l ure t o meet an LCO, the Requ i red Actions o f the associated Cond i t i ons sha l l be met, except as provided in LC0 3.0.5 and LC0 3.0.6.

I f the LC0 i s met or i s no longer appl i cab l e r ior t o expiration o f the specified Completion Time(s !

, completion o f the Requ i red Action(s) i s not requ i red unless otherwise stated.

When an LC0 i s not met and the associated ACT IONS are not met, an associated ACTION i s not provided, or i f d i rected by the associated ACT IONS, the un i t sha l l be p l aced i n a MODE or other spec i f ied condition i n which the LC0 i s not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> t o place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;

b. MODE 4 within 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />s: and c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Except ions t o t h i s Specification are stated i n the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LC0 or ACTIONS, completion o f the actions required by LC0 3.0.3 i s not required.

LC0 3.0.3 i s only applicable in MODES 1, 2, 3, and 4.

LC0 3.0.4 When an LC0 i s not met, entry into a MODE or other specified condition i n the Applicability shall only be made:

a. When the associated ACT1 ONS t o be entered permit continued operat ion i n the MODE or other specific condition in the Appl icabi l i t y f o r an unl imited period o f

time, (cont i nued)

North Anna Units 1 and 2 3.0-1

LC0 APPLICABILITY 3.0 3.0 LC0 APPLICABILITY Test Exception LCOs 3.1.9 and 3.4.19 allow specified Techn i ca l Spec i f i cat i on (TS) requ i rements t o be changed t o permit performance o f spec i a l tests and operat i ons. Un l ess otherw i se spec i f i ed, a l l other TS requ i rements rema i n unchanged. Comp l i ance with Test Except i on LCOs i s opt i ona l.

When a Test Except ion LC0 i s des i red t o be met but i s not met, the ACTIONS o f the Test Exception LC0 sha I I be met. When a Test Exception LC0 i s not desired t o be met, entry into a MODE or other specified condition i n the Applicability shall be made i n accordance with the other applicable Specifications.

LC0 3.0.8 When one or more required snubbers are unable t o perform the i r assoc i ated support funct i on (s), any affected supported LCO(s) are not requ i red t o be declared not met solely f o r t h i s reason i f r i s k i s assessed and managed, and:

a. the snubbers not able t o perform t h e i r associated support funct ion(s) are associated with only one t r a i n or subsystem o f a multiple t r a i n or subsystem supported system or are associated with a s i ng l e t r a i n o r subsystem supported system and are able t o perform t h e i r associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; o r

b. the snubbers not able t o perform thei r associated support funct ion(s) are associated with more than one t r a i n or subsystem o f a multiple t r a i n o r subsystem supported system and are able t o perform t h e i r associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

A t the end o f the specified period the requ i red snubbers must be able t o perform thei r associated support funct i on(s), o r the affected supported system LCO(s) shall be declared not met.

North Anna Units 1 and 2

Serial No. 07-0360 Docket Nos. 50-3381339 (Serial No. 07-0360)

Marked-up Technical Specifications Bases Changes (For Information Only)

North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

LC0 Appl i cabi 1 i t y 6 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES

/

LCOs LC0 3.0.1 through LC0 3.0.Bestabl i s h the general requirements appl icabl e t o a1 1 Specifications and apply a t a l l times, unless otherwise stated.

LC0 3.0.1 LC0 3.0.1 establishes the A p p l i c a b i l i t y statement w i t h i n each individual Specification as the requirement f o r when the LC0 i s required t o be met (i.e.,

when the u n i t i s i n the MODES o r other specified conditions o f the Appl i cabi 1 i t y statement o f each Specification).

LC0 3.0.2 LC0 3.0.2 establishes t h a t upon discovery o f a f a i l u r e t o meet an LCO, the associated ACTIONS shall be met. The Completion Time o f each Required Action f o r an ACTIONS Condition i s applicable from the p o i n t i n time t h a t an ACTIONS Condition i s entered. The Required Actions establ i s h those remedial measures t h a t must be taken w i t h i n specified Completion Times when the requirements o f an LC0 are not met.

his Specification establ i shes that:

a. Completion o f the Required Actions w i t h i n Completion Times constitutes compl iance w Speci f i cat i on; and the specified i t h a

b. Completion o f the Required Actions i s not an LC0 i s met w i t h i n the specified Comple unless otherwise specified.

required when t i o n Time, There are two basic types o f Required Actions. The f i r s t type o f Required Action specifies a time l i m i t i n which the LC0 must be met. This time 1 i m i t i s the Completion Time t o restore an inoperable system o r component t o OPERABLE status o r t o restore variables t o w i t h i n specified l i m i t s. I f t h i s type o f Required Action i s not completed w i t h i n the specified Completion Time, a shutdown may be required t o place the u n i t i n a MODE o r condition i n which the Specification i s not applicable. (Whether stated as a Required Action o r not, correction o f the entered Condition i s an action t h a t may always be considered upon entering ACTIONS.) The second type o f Required Action specifies the remedial measures t h a t permit continued operation o f the (continued)

North Anna Units 1 and 2 0 3.0-1 Revision 0

LC0 Appl i cabi 1 i t y B 3.0 BASES LC0 3.0.7 The Appl icabi 1 i t y o f a Test Exception LC0 represents a (continued) condition not necessarily i n compliance w i t h the normal requirements of the TS. Compliance w i t h Test Exception LCOs i s optional. A special operation may be performed e i t h e r under the provisions o f the appropriate Test Exception LC0 o r under the other applicable TS requirements. I f i t i s desired t o perform the special operation under the provisions o f the Test Exception LCO, the requirements o f the Test Exception LC0 shall be f o l l owed.

North Anna Units 1 and 2 Revision 0

INSERT 2 - Bases LC0 3.0.8 LC0 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LC0 states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for control by the licensee.

If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LC0 3.0.2.

LC0 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LC0 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

LC0 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LC0 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

In order to use LC0 3.0.8 for an inoperable snubber(s) the following conditions required by the NRC must be satisfied:

At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), must be OPERABLE when LC0 3.0.8.a is used.

At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s) must be OPERABLE, or some alternative means of core cooling (e.g., feed and bleed, fire water system, or "aggressive secondary cooldown" using the steam generators) must be available when LC0 3.0.8.b is used.

Confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.

LC0 3.0.8 does not apply to non-seismic snubbers.

addition, LC0 3.0.8 requires that risk be assessed and managed.

Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4)

(the Maintenance Rule) does not address seismic risk. However, use of LC0 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.