ML092950318

Email TSTF 490 E Bar Definition and RCS Specific Activity - Request for Additional Information

ML092950318
Person / Time
Site:	North Anna
Issue date:	10/21/2009
From:	V Sreenivas Plant Licensing Branch II
To:	Heacock D Virginia Electric & Power Co (VEPCO)
Sreenivas V.NRR/DORL/LPL2-1 415-2597
References
Download: ML092950318 (3)

Text

From: Sreenivas, V Sent: Wednesday, October 21, 2009 5:04 PM To: 'david.heacock@dom.com' Cc: 'Tom Shaub'; Taylor, Robert; Benton, Laray; Boatright, Aleem; Hughey, John; Cotton, Karen; Kulesa, Gloria; Blumberg, Mark; Blechman, Paula

Subject:

North Anna Unit 1 and 2: TSTF 490 E Bar definition and RCS Specific Activity -

Request for Additional Information (RAI)

Dear Mr. Heacock:

By letter dated December 17, 2008 (Agencywide Documents and Access Management System Accession No. ML083530982), Virginia Electric and Power Company submitted a license amendment for North Anna Power Station, Unit 1 and 2. The proposed amendment will revise Technical Specification (TS) to adopt Technical Specification Task Force (TSTF) - 490, "Deletion of E Bar Definition and Revision to RCS Specific Activity," for North Anna Power Station, Unit Nos. 1 and 2. The proposed changes would replace the current Technical Specification 3.4.16 limit on RCS gross specific activity with a new limit on RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent XE-133 definition that would replace the current E Bar average disintegration energy definition.

To complete its review of the proposed modification and the TSs changes, the Nuclear Regulatory Commission staff requests the licensees response to the following Request For Additional Information (RAI) questions:

In the subject license amendment request, the licensee proposed TS changes to revise Limiting Condition for Operation (LCO) 3.4.16, RCS Specific Activity, APPLICABILITY requirements to specify that the LCO is applicable in MODES 1, 2, 3, and 4. In accordance with this proposal, the licensee also proposed to add the NOTE that states, Only required to be performed in MODE 1. to the surveillance requirements of the TS, thus removing the applicability of the surveillance requirements to other MODES.

The NRC staff has a concern about the proposed addition of the aforementioned NOTE. The proposed change revises the conditions for sampling, and may exclude sampling during the plant conditions where LCO 3.4.16 may be exceeded. After transient conditions (i.e. reactor trip, plant depressurization, shutdown or startup) that end in MODES 2, 3, or 4, the SR is not required to be performed. Isotopic spiking and fuel failures are more likely during transient conditions than during steady state plant operations.

Because LCO 3.4.16 could potentially be exceeded after plant transient or power changes, please justify why sampling is no longer needed in the plant MODES that are proposed to be eliminated and justify how the LCO 3.4.16 remains consistent with the design bases analysis from which the LCO limits are derived (i.e. main steamline break, steam generator tube rupture, etc.). Furthermore, please justify why there is an apparent disparity between the modes of applicability (MODES 1, 2, 3, and 4) and the limited mode (MODE 1) under which the surveillance is required.

Please provide response to these RAI by November 21st, 2009. If you have any questions, please contact me at (301) 415-2597.

Sincerely, VSreenivas V. Sreenivas, PH.D., C.P.M.,

Project Manager, DORL/LPL2-1, (North Anna Nuclear Power Station)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission (301) 415-2597, v.sreenivas@nrc.gov Mail Stop: O8-G9A Docket No.: 50-338 and 50-339 Dated: October 21, 2009 E-mail Properties Mail Envelope Properties (AF843158D8D87443918BD3AA953ABF78151B81A9)

Subject:

North Anna Unit 1 and 2: TSTF 490 E Bar definition and RCS Specific Activity -Request for Additional Information (RAI)

Sent Date: 10/21/2009 5:04:01 PM Received Date: 10/21/2009 5:04:01 PM From: Sreenivas, V Created By: V.Sreenivas@nrc.gov Recipients:

david.heacock@dom.com ('david.heacock@dom.com')

Tracking Status: None tom.shaub@dom.com ('Tom Shaub')

Tracking Status: None Robert.Taylor@nrc.gov (Taylor, Robert)

Tracking Status: None Laray.Benton@nrc.gov (Benton, Laray)

Tracking Status: None Aleem.Boatright@nrc.gov (Boatright, Aleem)

Tracking Status: None John.Hughey@nrc.gov (Hughey, John)

Tracking Status: None Karen.Cotton@nrc.gov (Cotton, Karen)

Tracking Status: None Gloria.Kulesa@nrc.gov (Kulesa, Gloria)

Tracking Status: None Mark.Blumberg@nrc.gov (Blumberg, Mark)

Tracking Status: None Paula.Blechman@nrc.gov (Blechman, Paula)

Tracking Status: None Post Office:

HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 26806 10/21/2009 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: