Text

Annual Submittal of Technical Specification Bases Changes Pursuant to Technical Specification 5.5.13.d
	ML15289A388
Person / Time
Site:	North Anna
Issue date:	10/02/2015
From:	Hilbert L; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15289A387	List: ML15289A388; ML15289A389;
References
	15-474
	Download: ML15289A388 (8)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 2, 2015 U.S. Nuclear Regulatory Commission Serial No.15-474 Attention: Document Control Desk NAPS/JHL R0 Washington, D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2 ANNUAL SUBMITTAL OF TECHNICAL SPECIFICATION BASES CHANGES PURSUANT TO TECHNICAL SPECIFICATION 5.5.13.d Pursuant to Technical Specification 5.5.13 .d, "Technical Specifications (TS) Bases Control Program," Dominion hereby submits the changes to the Bases of the Technical Specifications implemented during the period of October 1, 2014 through September 30, 2015. A summary of these changes is provided in Attachments 1 and 2. Enclosed is an electronic copy (CD) of the entire TS Bases through Revision 56 for your information.

Bases changes to the Technical Specifications that were not previously submitted to the NRC as part of a License Amendment Request were reviewed and approved by the Facility Safety Review Committee. It was determined that these changes did not require a change to the Technical Specifications or license, or involve a change to the UFSAR or Bases that required NRC prior approval pursuant to 10CFR50.59. These changes have been incorporated into the TS Bases. A summary of these Bases changes is provided in Attachment 1.

TS Bases changes that were submitted to the NRC for information along with the associated License Amendment Request transmittals, submitted pursuant to 10OCFR50.90, were also reviewed and approved by the Facility Safety Review Committee. These changes have been implemented with the respective License Amendments. A summary of these changes is provided in Attachment 2.

If you have any questions regarding this submittal, please contact Mr. Page Kemp at (540) 894-2295.

Sincerely,

/ 4(o.cf..*

L. A. Hilbert Director, Nuclear Safety and Licensing 1

Attachments

1. Summary of TS Bases Changes Not Previously Submitted to the NRC

2. Summary of TS Bases Changes Associated with License Amendments Enclosure - CD of Current TS Bases (Revision 56)

Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, Georgia 30303-1 257 Mr. J. E. Reasor, Jr. (without Enclosure)

Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060 State Health Commissioner (without Enclosure)

Virginia Department of Health James Madison Building- 7t Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Dr. V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, Maryland 20852-2738 Ms. K. R. Cotton NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, Maryland 20852-2738 NRC Senior Resident Inspector (without Enclosure)

North Anna Power Station

ATTACHMENT 1

SUMMARY

OF TS BASES CHANGES NOT PREVIOUSLY SUBMITTED TO THE NRC VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2

SUMMARY

OF TS BASES CHANGES NOT PREVIOUSLY SUBMITTED TO THE NRC Revise the Bases of Technical Specification 3.8.1 to Reflect that Regulatory Guide 1.108 was Replaced by Regulatory Guide 1.9 The change revised the Bases of Technical Specification (TS) Surveillance Requirements (SR) 3.8.1, 3.8.1.10, 3.8.1.13, and 3.8.1.15 to reflect that Regulatory Guide 1.108 (Ref. 8) was subsequently replaced by Regulatory Guide 1.9. Regulatory Guide 1.9, Rev. 3, July 1993 was added as Reference 13. The proposed changes are to maintain the licensing basis current.

Revision of Technical Specification Bases Section 3.6.7.3 The Technical Specification (TS) Bases was previously revised as a result of Amendment 218. Amendment 218 deleted a Note from the TS Surveillance Requirement (SR) 3.6.7.3 regarding the old Casing Cooling Tank boron concentration limits of 2300 - 2400 ppm for North Anna Unit 2. This same note was not deleted from the equivalent Bases section.

Revision of Technical Specification Bases Section 3.3.3 The Bases of Technical Specification (TS) 3.3.3 was clarified regarding Containment Isolation Valves (CIVs) with two sets of indication in the Main Control Room (MOR).

Limiting Condition for Operation (LCO) 3.3.3 requires two operable channels for most Post Accident Monitoring (PAM) Instrumentation Functions. Two operable channels ensure no single failure prevents operators from getting the information necessary to determine the safety status of the unit, and to bring the unit to and maintain it in a safe condition following an accident. Furthermore, operability of two channels allows a channel check during the post accident phase to confirm the validity of displayed information.

The exception to the two channel requirement is CIV position. In this case, the important information is the status of the containment penetrations. Note (b) of the TS requires one position indicator for each penetration flow path with only one installed control room indication channel. This is sufficient to redundantly verify the isolation status of each isolable penetration either via indicated status of the active valve and prior knowledge of a passive valve, or via system boundary status. If a normally active CIV is known to be closed and deactivated, position indication is not needed to determine status. Therefore, the position indication for valves in this state is not required to be operable.

However, there is no specific guidance provided in the TS Bases for penetrations with one CIV that has two sets of indication in the control room. These CIVs do not fall under the same exception as the penetrations with one CIV with one set of indication.

'I Because per the two one CIV requirement the channel has two setsofofLCO indication, 3.3.3. both The sets Noteof (b) indication does notareapply required as in this scenario. As such, additional wording was added to the Bases of TS 3.3.3 to clarify this fact and that both channels of indication for a single CIV are required to be operable.

Administrative Correction to the Bases of Technical Specification Surveillance Requirement 3.4.1 6.2 to Correct a Typographical Error Technical Specification 3.4.16 is for Reactor Coolant System (RCS) Specific Activity.

Surveillance Requirement 3.4.16.2 verifies reactor coolant dose equivalent Iodine-131 (I-131) specific activity is less than or equal to 1.0 microcurie per gram. The frequency of sampling is controlled by the Surveillance Frequency Control Program and when a thermal power change of greater than or equal to 15% rated thermal power (RTP) occurs within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period. Following the latter, the sampling must occur between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after the power change. Sampling at other times would provide inaccurate results. Currently, the Bases states "samples at other times would provide accurate results." The word "accurate" was changed to "inaccurate." The wording correction was verified by consulting NUREG-1431.

ATTACHMENT 2

SUMMARY

OF TS BASES CHANGES ASSOCIATED WITH LICENSE AMENDMENTS VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2

SUMMARY

OF TS BASES CHANGES ASSOCIATED WITH LICENSE AMENDMENTS Modification of Control Bank Sequence and Overlap Technical Specification The amendment revised Technical Specification 3.1.6, "Control Bank Insertion Limits,"

to include text, into Condition A stating, "for reasons other than Condition C". The TS change points to Condition C which, if applicable, allows the specified completion time to restore the control bank to within the insertion limit to be increased from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The TS Bases were revised to reflect the insertion of text into Condition A stating "for reasons other than Condition C". The discussion in the Bases of Condition C was revised to reflect that if Control Banks A, B, or C are inserted below the insertion limits or sequencing or overlap limits are not met, power operation may continue for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided that the bank is not inserted more than 18 steps below the insertion limits, the control and shutdown rods are within the operability and rod group alignment requirements provided in Limiting Condition for Operation (LCO) 3.1.4, and the shutdown banks are within the insertion limits provided in LCO 3.1.5.

The Bases changes noted above were submitted to the NRC by Dominion submittal dated February 22, 2013 and incorporated into the Bases for North Anna Units 1 and 2 on October 7, 2014 upon' NRC approval and implementation of the associated Technical Specification changes (Amendments 272 for Unit 1 and 254 for Unit 2 issued on August 27, 2014).

Alternate Rod Position Monitoring The amendment revised Technical Specification 3.1.7, "Rod Position Indication," to include an additional monitoring option for an inoperable control rod position indicator.

Specifically, the changes allow monitoring of control rod drive mechanism (CRDM) stationary gripper coil voltage every eight hours as an alternative to using the movable incore detectors every eight hours to verify control rod position.

The TS Bases were revised to reflect in the Limiting Condition for Operation (LCO) section that rod position indication for a single rod can be determined by measuring the CRDM stationary gripper coil voltage using a temporary recorder that provides alarm capability.

A discussion of a new Note for new Required Actions A.3.1 and A.3.2 was added to ensure that the alternate monitoring requirements are not used as a long term means of verifying rod position. The intended use of this alternate is to allow for monitoring until plant entry into a Mode 5 outage of sufficient duration and repair of the RPI can be safely performed. This ensures that at most, the alternate is used for 18 months or one operating cycle.

I A discussion of new Required Action A.3.1 was provided. When one RPI fails, the position of the rod can still be determined by use of the movable incore detectors.

Based on experience, normal power operation does not require excessive movement of banks. If a bank has been significantly moved, the Required Action of C.1 or C.2 below is required. Therefore, verification of control rod position within the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small. To provide verification of reliability of alternate monitoring, rod position will be verified by moveable incore detectors every 31 days. The 31-day frequency minimizes use of the movable incore monitoring system and can be performed concurrently with existing surveillance requirements for Hot Channel Factors.

A discussion of new Required Action A.3.2 was provided. Review of control rod primary coil stack voltage using the alternate monitoring method for indication of control rod movement for the rod with inoperable position indicator will be within 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months and then every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Verification of control rod position within the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small. Should primary coil stack voltage of the control rod indicate movement, a determination of the control rod position will be made using the moveable incore detectors within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . To provide verification of reliability of alternate monitoring, rod position will be verified by moveable incore detectors every 31 days.

The 31-day frequency minimizes use of the movable incore monitoring system and can be performed concurrently with existing surveillance requirements for Hot Channel Factors.

The Bases changes noted above were submitted to the NRC by Dominion submittal dated February 4, 2015 and incorporated into the Bases for North Anna Units 1 and 2 on May 21, 2015 upon NRC approval and implementation of the associated Technical Specification changes (Amendments 273 for Unit 1 and 255 for Unit 2 issued on May 14, 2015).