ML18029A118

Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month

ML18029A118
Person / Time
Site:	North Anna
Issue date:	01/22/2018
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
17-430
Download: ML18029A118 (27)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 22, 2018

,\,,

United States Nuclear Regulatory Commission Serial No.: 17-430 Attention: Document Control Desk *NL&OS/RAP: Rev. 0 Washington, D. C. 20555 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)

NORTH ANNA POWER STATION UNITS 1 AND 2 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522, REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH In accordance with the provisions of 10 CFR 50.90, Dominion Energy Virginia is submitting a request for an amendment to the Technical Specifications (TS) for North Anna Power Station (NAPS) Units 1 and 2.

The proposed amendment would modify TS requirements to operate ventilation systems with charcoal filters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month in accordance with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month." Additionally, an administrative change is being made to the Environmental Protection Plan (EPP) to reflect current code numbering.

Attachment 1 provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked-up to show the proposed changes. Attachment 3 provides revised (clean) TS pages showing the proposed changes. Attachment 4 provides existing TS Bases pages marked-up to show the proposed changes.

Attachment 4 is provided for information only. Final TS Bases changes will be processed in accordance with the TS 5.5.13, "Bases Control Program," at the time the amendment is issued.

Dominion Energy Virginia has evaluated the proposed amendment and determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. The basis for this determination is included in Attachment 1. Dominion Energy Virginia has also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

The proposed license amendment has been reviewed and approved by the NAPS Facility Safety Review Committee.

Dominion Energy Virginia requests approval of the proposed license amendment by January 1, 2019, with the amendment being implemented within 60 days.

Serial No.17-430 Docket Nos.: 50-338/339 Page 2 of 3 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Virginia State Official.

.. If you have any questions or require additional information, please contact Ms. Diane Aitken at (804) 273-2694.

Very truly yours, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Attachments

1. Discussion of Change

2. Marked-up Technical Specifications Pages

3. Proposed Technical Specifications Changes Pages

4. Marked-up Technical Specifications Bases Pages (for information only)

Commitments made in this letter: None COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and *for the County and Commonwealth aforesaid, today by M. D. Sartain who is Vice President - Nuclear Engineering and Fleet Support 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 ;i..l.. day of Jwub'C"j , 2018.

My Commission Expires: Guj""_.s.,t ~\.20lq,

Serial No.17-430 Docket Nos.: 50-338/339 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303 NRC Senior Resident Inspector North Anna Power Station State Health Commissioner Virginia Department of Health James Madison Building - ih floor 109 Governor Street Suite 730 Richmond, Virginia 23219 Mr. J. R. Hall NRC Project Manager - North Anna U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, MD 20852-2738 Ms. K. R. Cotton Gross NRC Project Manager - Surry U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G9A Rockville, MD 20852-2738 Mr. J. E. Reasor, Jr. (w/out attachment)

Old Dominion Electric Cooperative Innsbrook Corporate Center Suite 300 4201 Dominion Blvd.

Glen Allen, VA 23060

Serial No.17-430 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion Energy Virginia)

Serial No.17-430 Docket Nos. 50-338/339

• 1.0 Description The proposed change revises the Surveillance Requirements (SR) which

• currently require operating ventilation systems with the heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days. The SRs are revised to require

. operation of the systems for 15 continuous minutes every 31 days.

• *. The proposed .amendment is consistent with TSTF-522, Revision 0, "Revise Ventilation System*'surveillance Requirements to Operatef6r 1O hours per Month." * **

2.0 Assessment 2.1 Applicability of Published Safety Evaluation Dominion Energy Virginia has reviewed the model safety evaluation dated September 13, 2012 as part of the Federal Register Notice of Availability. This review included a review of the NRC staff's evaluation, as Well as the information provided in TSTF-522, Revision 0. As described in the subsequent paragraphs, Dominion Energy Virginia has concluded that the justification presented in the TSTF-522, Revision O proposal and the model safety evaluation prepared by the NRC staff are applicable to North Anna Power Station (NAPS) and justify this amendment for the incorporation of the changes to the NAPS TS.

2.2 Optional Changes and Variations Dominion Energy Virginia is proposing the following variations from the TS changes described in the TSTF-522, Revision 0, or the applicable parts of the NRC staff's model safety evaluation dated September 13, 2012.

As noted in the NRC's model safety evaluation, some plants have adopted TSTF-425, which relocated the fixed SR Frequencies to a licensee-controlled program, the Surveillance Frequency Control Program (SFCP). The NAPS TS were revised to adopt the SFCP in License Amendment 262/243. Thus, the proposed changes are consistent with the current NAPS licensing basis, the NRC's model safety evaluation, and therefore, is an allowable variation from the approved Traveler.

In addition, Dominion Energy Virginia is proposing to modify the requirements in the Ventilation Filter Testing Program (VFTP), TS 5.5.10, to remove the electric heater output test (TS 5.5.1 O.e) and to increase the specified relative humidity (RH) for the charcoal testing for the MCR/ESGR EVS from the current 70% to 95% RH in TS 5.5.1 O.c. The more stringent RH requirement will mean the heaters will no longer be relied upon to remove the additional moisture from the incoming air. This proposed change is consistent with TSTF-522, Revision 0, as the Standard TS (NUREG-1431) on which the Traveler is based, contains both options of with and without humidity control (i.e. electrical heaters) as bracketed Page2

Serial No.17-430 Docket Nos. 50-338/339 versions of the SR. The NRC's model safety evaluation also acknowledges both options are allowed, as this is consistent with current Staff guidance in Regulatory Guide 1.52, Revision 3. Therefore, this proposed change is consistent with the approved Traveler and model safety evaluation and does not constitute a technical deviation.

Additionally, an administrative change is being made to the Environmental Protection Plan (EPP) to reflect current code numbering. The specific change is updating 10 CFR 50.72(b)(2)(vi) to the current code numbering of 10 CFR 50.72(b)(2)(xi). *

• 3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration NAPS, Units 1 and 2 requests adoption of an approved change to the standard technical specifications (STS) and pla_nt specific TS, to revise TS 3.7.10, "Control Room Emergency Filtration System (MCR/ESGR EVS)," and TS 3.7.12, "Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS)," in the ISTS for Westinghouse plants (NUREG-1431) from operating the MCR/ESGR EVS and ECCS PREACS with the electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days to require operation of the systems for 15 continuous minutes every 31 days. In addition, the requirements in the VFTP, TS 5.5.10, will be revised to remove the electric heater output test (TS 5.5.1 O.e) and to increase the specified relative humidity (RH) for the charcoal testing for the MCR/ESGR EVS from the current 70% to 95% RH in TS 5.5.1 O.c.

Additionally, an administrative change is being made to the EPP to reflect current code numbering.

The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change replaces existing SRs to operate the MCR/ESGR EVS and ECCS PREACS Systems equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes every 31 days with heaters operating, if needed. In addition, the electrical heater output test in the VFTP (TS 5.5.10.e) is proposed to be removed and a corresponding change in the charcoal filter testing (TS 5.5.1 O.c) be made to require testing be conducted at a humidity of at least 95% RH, which is more stringent than the current testing requirement of 70% RH.

Page 3

Serial No.17-430 Docket Nos. 50-338/339 These systems are not accident initiators and therefore, these changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function which may include mitigating accidents. Thus, the change does not involve a significant increase in the consequences of an accident.

The change to the EPP is administrative in nature to reflect approved NRC references (codes).

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change replaces existing SRs to operate the MCR/ESGR EVS and ECCS PREACS Systems equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes every 31 days with heaters operating, if needed. In addition, the electrical heater output test in the VFTP (TS 5.5.10.e) is proposed to be removed and a corresponding change in the charcoal filter testing (TS 5.5.1 O.c) be made to require testing be conducted at a humidity of at least 95% RH, which is more stringent than the current testing requirement of 70% RH.

The change proposed for these ventilation systems does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components are capable of performing their intended safety functions. The change dbes not create new failure modes or mechanisms and no new accident precursors are generated.

The change to the EPP is administrative in nature to reflect approved NRC references (codes).

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page4

Serial No.17-430 Docket Nos. 50-338/339

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change replaces existing SRs to operate the MCR/ESGR EVS and ECCS PREACS Systems equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period every 31 days with a requirement to operate the systems for 15 continuous minutes every 31 days with heaters operating, if needed. In addition, the electrical heater output test in the VFTP (TS 5.5.10.e) is proposed to be removed and a corresponding change in the charcoal filter testing (TS 5.5.1 O.c) be made to require testing be conducted at a humidity of at least 95% RH, which is more stringent than the current testing requirement of 70% RH.

The proposed increase to 95% RH in the required testing of the MCR/ESGR EVS charcoal filters compensates for the function of the heaters, which was to reduce the humidity of the incoming air to below the currently-specified value of 70% RH for the charcoal. The proposed change is consistent with regulatory guidance and continues to ensure that the performance of the charcoal filters is acceptable.

The change to the EPP is administrative in nature to reflect approved NRC references (codes).

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the above, Dominion Energy Virginia concludes that the proposed change presents no significant hazards considerations under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 Environmental Consideration A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Page 5

Serial No.17-430 Docket Nos.: 50-338/339 Attachment 2 Marked-up Technical Specificatlons Pages 5.

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

MCR/ESGR EVS 3.7.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. (continued)

• OR

~

Two required MCR/ESGR EVS trains inoperable during movement of recently irradiated fuel assemblies for reasons other than Condition B.

F. Two required MCR/ESGR F.l Enter LCO 3.0.3. Irrrnediately EVS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each required MCR/ESGR EVS train In accordance for ~L}~continuous hour~* the heaters with the Vf"'""' \AILI II 1 ~ =-

Surveillance Frequency 15 minutes! Control Program SR 3.7.10.2 Perform required MCR/ESGR EVS filter In accordance testing in accordance with the Ventilation with VFTP Filter Testing Program (VFTP).

SR 3.7.10.3 Not Used North Anna Units 1 and 2 3.7.10-3 Amendments 262/243

ECCS PREACS 3.7.12 ACTIONS CONDITION REQUIRED ACTION K:OMPLETION TIME D. Two ECCS PREACS trains D.1.1 Verify ECCS leakage 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable due to log is less than the inoperable ECCS pump room maximum allowable boundary affecting unfiltered leakage.

filtration capability.

AND D.1.2 Verify by field Once per walkdown that ECCS 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage is less than thereafter the maximum allowable unfiltered leakage.

AND D.1.3 Restore ECCS pump room 14 days boundary to OPERABLE status.

OR D.2 Restore ECCS pump room 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> boundary to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND E.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Operate each ECCS PREACS train for In accordance with the

~ }O continuous oot:tt's- with the Surveillance Frequency hea ,ers operating. Control Program North Anna Units 1 and 2 3.7.12-4 Amendments 262/243

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Ventilation Filter Testing Program (VFTP)

c. (continued}

value specified below when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) and relative humidity specified below.

ESF Ventilation System Penetration RH MCR/ESGR EVS 2.5% 7-0%~

ECCS PREACS 5% 70%

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with ANSI N510-1975 at the system flowrate specified below.

ESF Ventilation System Delta P Flowrate MCR/ESGR EVS 4 inches W.G. 1000 +/- 10% cfm ECCS PREACS 5 inches W.G. ~ 39,200 cfm

e. Demonstrate that the heaters for each of the ESF systems dissipate~ the value specified below when tested in accordance

[ with ASME N510-1975.

(iemove ESF Ventilation System Wattage MCR/ESGR EVS 3. 5 k\ol The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.11 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Gaseous Waste System, the quantity of radioactivity contained in gas storage tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The gaseous radioactivity quantities sha11 be determined fo1lowing the methodology in Branch Technical Position (BTP) ETSB 11-5, 11 Postulated Radioactive Release due to Waste Gas System Leak or

• (continued)

North Anna Units. 1 and 2 5.5-11 Amendments 269/250

02-20-96 4.0 Environmental Conditions 4.1 Unusual or Important Environmental Events Any occun"ence of an unusual or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and promptly reported to the NRC in accordance with 10 CPR 50.72(b)(2)(vij_fol~d by a writt~n report as specified in

~

Subsection 5.4.2. The following are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protected by the Endangered Species Act of 1973, fish kills, significant increase in nuisance organisms or conditions and unanticipated or emergency discharge of waste water or chemical substances.

4.2 Environmental Monitoring 4.2.1

• Herbicide Application The use of herbicides within the corridor rights-of-way as described and evaluated in the FES-OL dated April 1973 shall conform to the approved use of selected herbicides as registered by the Environmental Protection Agency and approved by State authorities and applied as directed by said authorities.

Records shall be maintained in the appropriate division office concerning herbicide use. Such records shall include the following information: commercial and chemical names of materials used; concentration of active material in formulations diluted for field use; diluting substances other than water; rates of application; method and frequency of application; location; and the date of application. Such records shall be maintained for a period of 5 years and be made readily available to the NRC upon request. There shall be no routine reporting requirement associated with this condition.

NORTH ANNA - UNIT 1 4-1 Amendment No. ~. 197

02-20~96 4.0 Environmental Conditions 4.1 Unusual or Important Environmental Events Any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and promptly reported to the NRC in accordance with 10 CFR 50.72(b)(2)(vi) fol d by a written report as specified in xi Subsection 5.4.2. The following are examples: excessive 1r impaction events, onsite plant or animal disease outbreaks, mortality or unusual occmTence of any species protected by the Endangered Species Act of 1973, fish kills, significant increase in nuisance organisms or conditions and unanticipated or emergency *discharge of waste water or chemical substances.

4.2 Environmental Monitoring 4.2.1 Herbicide Application The use of herbicides within the co1Tidor rights-of-way as described and evaluated in the FES-OL dated April 1973 shallconform to the approved use of selected herbicides as registered by the Environmental Protection Agency and approved by State authorities and applied as directed by said authorities.

Records shall be maintained in the appropriate division office concerning herbicide use. Such \

records shall include the following information: commercial and chemical names of materials used; concentration of active material in formulations diluted for field use; diluting substances other than water; rates of application; method and frequency of application; location; and the date of application. Such records shall be maintained for a period of 5 years and be made readily available to the NRC upon request. There shall be no routine reporting requirement associated with this condition.

NORTH ANNA" UNIT 2 4-1 Amendment No.~. 178

Serial No.17-430 Docket Nos.: 50-338/339 Attachment 3 Proposed Technical Specifications Changes Pages North Anna Power Station .

Units 1 and 2 Virginia Electric and Power Company (Dominion Energy Virginia)

MCR/ESGR EVS 3.7 .10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. (continued)

OR Two required MCR/ESGR EVS trains inoperable during movement of recently irradiated fuel assemblies for reasons other than Condition B.

F. Two required MCR/ESGR F.1 Enter LCO 3.0.3. Irrrnediately EVS trains inoperable in MOOE 1, 2, 3, or 4 for reasons other than Condition B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each required MCR/ESGR EVS train In accordance for~ 15 continuous minutes. with the Surveillance Frequency .

Control Program SR 3.7.10.2 Perform required MCR/ESGR EVS filter In accordance testing in accordance with the Ventilation with VFTP Filter Testing Program {VFTP).

SR 3.7.10.3 Not Used North Anna Units 1 and 2 3. 7 .10-3 Amendments

ECCS PREACS

3. 7 .12 ACTIONS CONDITION REQUIRED ACTION ~OMPLETION TIME

0. Two ECCS PREACS trains D.1.1 Verify ECCS leakage 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable due to log is less than the inoperable ECCS pump room maximum a11 owab1e boundary affecting unfiltered leakage.

filtration capability.

AND D.1.2 Verify by field Once per walkdown that ECCS 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage is less than thereafter the maximum a11 owab le unfiltered leakage.

AND D.1.3 Restore ECCS pump room 14 days boundary to OPERABLE status.

OR D.2 Restore ECCS pump room 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> boundary to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND E.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Operate each ECCS PREACS train for In accordance with the

~ 15 continuous minutes with the Surveillance Frequency heaters operating. Control Program North Anna Units 1 and 2 3.7.12-4 Amendments

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.10 Ventilation Filter Testing Program (VFTP)

c. (continued) value specified below when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) and relative humidity specified belol'/,

ESF Ventilation System Penetration RH MCR/ESGR EVS 2.5% 95%

ECCS PREACS 5% 70%

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with ANSI NSl0-1975 at the system flowrate specified below.

ESF Ventilation System Delta P Flowrate MCR/ESGR EVS 4inches H.G. 1000 +/- 10% cfm ECCS PREACS 5 inches \il.G. ~ 39,200 cfm The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.11 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Gaseous Waste System, the quantity of radioactivity contained in gas storage tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or (continued)

North Anna Units 1 and 2 5.5-11 Amendments

4.0 Environmental Conditions 4.1 Unusual or Important Environmental Ev_ents Any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and promptly reported,*

to the NRC in accordance with 10 CFR 50.72(b )(2)(xi) followed by a written report as specified in. - I Subsection 5.4.2. The following are examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occun-ence of any species protected by the Endangered Speci~s Act of 1973, fish kills, significant increase in nuisance orga.nisms or conditions and unanticipated or emergency discharge of waste water or chemical substances.

4.2 Environmental Monitoring 4.2. l Herbidde Application The use of herbicides within the coni~or rights-of-way as described and evaluated in the FES-OL dated April 1973 shall conform to the approved use of selected herbicides as registered by the Environmental Protection Agency and approv~d by State authorities and applied as directed by said authorities.

Records shall be maintained in the appropriate division office concerning herbicide use. Such records shall include the foilowing information: coQ1II1ercial and chemical names of materfals used; concentration of active material in formulations diluted for field use; diluting substances other than water; rates of application; method and frequency of application; location; and the date of applicatio.n. Such records shall be maintained for a period of 5 years and be made readily available to the NRC upon request. Tifore shall be no routine reporting requiremel).t associated with this condition.

NORTH.ANNA - UNlT 1 4-1 . Amendment No. 2-3-, +9+

4.0 Environmental Condiiions 4.1 Unusual or Important Environmental Events Any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to plant operation shall be recorded and promptly reported to the NRC in accordance with 10*cFR 50.72(b)(2)(xi) followed by a written report as specified.in Subsection 5.4.2. The following are examples: excessi~_(}. bird impaction events, onsite plant or.

animal disease outbreaks, mortality or unusual occunence of any species protected by the Endangered Species Act of 1973, fish kills, significant increase in nuis-ance org.anisms or conditions and unanticipated or emergency discharge of waste water or chemical substances.

4.2 Environmen.tal Monitoring 4.2.1 Herbicide Application The use of herbicides within the corridor rights-of-way as described and evaluated in the FES-OL dated April 1973 shall conform to the approved use of selected herbicides as registered by_ the*

Environmental Protection Agency and approved by State authorities and applied as directed by said authorities.

Records shall be maintained in the appropriate division office concerning herbicide use. Such records shall include the following information: commercial and chemica.1 names of materials used; concentration of active material in formulations diluted for field use; diluting substances other than water; rates of application; method and frequency of application; loc~tion; and the date of application. Such records shall be maintained for a period of 5 years and be made readily available to the NRC upon request. There shall be no routine reporting requirement associated w~th this condition.

NORTH ANNA*- UNIT 2 4-1 Amendment No. i, 178

Serial No.17-430 Docket Nos.: 50-338/339 Attachment 4 Marked-up Technical Specifications Bases Pages (for information only)

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

MCR/ESGR EVS B 3.7.10 BASES BACKGROUND events, and accident conditions. The MCR/ESGR envelope (continued) boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the MCR/ESGR envelope. The OPERABILITY of the MCR/ESGR envelope boundary must be maintained to ensure that the inleakage of unfiltered air into the MCR/ESGR enve 1ope wi1 l not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to MCR/ESGR envelope occupants. The MCR/ESGR envelope and its boundary are defined in the MCR/ESGR Envelope Habitability Program.

Upon receipt of an actuating signal(s) (i.e., SI, fuel building radiation monitors or manual), normal air supply to and exhaust from the MCR/ESGR envelope is isolated, and at least two trains of MCR/ESGR EVS receive a signal to actuate to recirculate air in the MCR/ESGR envelope. Approximately 60 minutes after actuation of the MCR/ESGR Isolation Actuation Instrumentation, a single MCR/ESGR EVS train is manually actuated or aligned to provide filtered outside air to the MCR/ESGR enve1ope through HEPA fi1 ters and charcoa 1 adsorbers. The demisters remove any entrained water droplets present, to prevent excessive moisture loading of the HEPA filters and charcoa 1 adsorbers. eortti 1ruous oper ati 011 of each train for at least 10 flours pet' month, Hith the heaters on, reduces moi stttl"e buildup on the IIEPA fi Hers and~dsor-bers.

demister aRd heater alle_important to the i eness of the HEPA fi1ter~~adsorbers.

The Although not assumed in the Analysis of RecorJ, pressurization of the MCR/ESGR envelope minimizes infiltration of unfiltered air through the MCR/ESGR envelope boundary from all the surrounding areas adjacent to the MCR/ESGR envelope boundary.

Redundant MCR/ESGR EVS supply and recirculation trains provide the required filtration of outside air should an excessive pressure drop develop across the other filter train.

(continued)

North Anna Units 1 and 2 B 3.7.10-2 Revision 39

MCR/ESGR EVS B 3.7.10 BASES LCO The MCR/ESGR EVS is considered OPERABLE when tlie individual (continued) components necessary to limit MCR/ESGR envelope occupant exposure are OPERABLE in the two required trains of the MCR/ESGR EVS. 1-HV-F-41 can not be used to satisfy the requirements of LCO 3.7.10.

An MCR/ESGR EVS train is OPERABLE when the associated:

a. Fan is OPERABLE; I b. Demister filters, HEPA filters and.charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; and

c. Heater, ~ctwork, va 1ves, and dampers are OPERABLE. and air fl ow can be maintained.

The MCR/ESGR EVS is shared by Unit 1 and Unit 2.

In order for the MCR/ESGR EVS trains to be considered OPERABLEi the MCR/ESGR envelope boundary must be maintained such that the MCR/ESGR envelope occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs. and that MCR/ESGR envelope occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a Note a11 owing the MCR/ESGR enve1ope boundary to be opened intermittently under administrative controls. This Note only applies to openings in the MCR/ESGR envelope boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous coll1llunication with the operators in the MCR/ESGR envelope.

This individual will have a method to rapidly close the opening and restore the MCR/ESGR envelope boundary to a condition equivalent to the design condition when a need for MCR/ESGR isolation is indicated.

North Anna Units 1 and 2 B 3.7.10-5 Revision 39

MCR/ESGR EVS B 3.7.10 BASES ACTIONS D.1.1, D.1.2, and D.2 (continued)

An a1ternative to Required Action D.1 is to irrrnediate1y suspend activities that present a potentia1 for releasing radioactivity that might require iso1ation of the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

E.1 During movement of recently irradiated fuel assemblies, if a required train of MCR/ESGR EVS train becomes inoperable due to an i noperab 1e MCR/ESGR enve 1ope boundary or two required MCR/ESGR EVS trains inoperable, action must be taken irrrnediately to suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

f~

When two required MCR/ESGR EVS trains are inoperable in MODE l, 2, 3, or 4 for reasons other than an inoperable MCR/ESGR envelope boundary (i.e., Condition B), the MCR/ESGR EVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses.

Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodi ca 11 y to ensure that they function properly. As the environment and normal operating conditions on the MCR/ESGR EVS are not too severe, testing each required train once every month provides an adequate check of this system. Monthly h e a ~

ottt aRy moisture accumulated 1l'l the ekal"eoal i:!Rd IIEP-A-fi lte1 s ft om liumi di ty i II the ambient air-; Each required :f--lminutes train must be operated for ~ W continuous lrom s with t~ 1 ltea-tePs ene~gized. The Surveil nee Frequency is based on operating experience, equipment reliability, and plant risk and :is controlled under the Sur eillance Frequency Control Program. 15 North Anna Units 1 and 2 B 3.7.10-8 Revision 46

MCR/ESGR EVS B 3.7.10 BASES SR ** 3.7 .10.4 (continued)

Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the MCR/ESGR envelope boundary has been restored to OPERABLE status.

REFERENCES 1. UFSAR, Section 6.4.

2. UFSAR, Chapter 15.

3. 10 CFR 50, Appendix A.

4. Control Room Habitability Study (Supplement to 1980 Onsite Control Room Habitability Study - North Anna Power Station Units 1 and 2, January 1982.

5. Letter from L.N. Hartz (Virginia Electric and Power Company) to the USNRC, dated March 3, 2004, Response to Generic Letter 2003-01, "Control Room Habitability -

Control Room Testing &Technical Information. 11

6. Regulatory Guide 1.196.

7. NEI 99-03, "Control RoomHabitabilityAssessment, 11 June 2001.

8. Letter from Eric J. Leeds (NRC) to James l*I. Davis (NEI) dated January 30, 2004, 11 NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Contro 1 Room Ha.bi tabi l *J ty. (ADAMS 11 Accession No. ML040300694) j9. TSTF-522 I North Anna Units 1 and 2 B 3.7.10-10 Revision 39

ECCS PREACS B 3,7,12 BASES ACTIONS D.2 (continued) is inoperable, appropriate compensatory measures consistent with. the intent of GDC 19 should be utilized to protect control room operators from potential hazards such as radioactive contamination. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most prob 1ems with the ECCS pump ro.om boundary.

• E.1 and E. 2 If the ECCS PREACS train(s) or ECCS pump room boundary cannot

. be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.12.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly, As the environment and normal operating conditions on this system are not severe, testing each train once a month provides an adequate check on this system. Monthly heater operations dry out any moisture that may have accumulated in the charcoal and HEPA filters from humidity in the ambient air. The system must be operated

~ 1ir continuous hettrs with the heaters energi.zed. The Sur. illance F_requ cy is based on operating experience, equi ment reliabili y, and plant risk and is controlled unde the Surveilla ce Frequency Control Program.

15 minutes North Anna Units 1 and 2 8 3.7.12-9 Revision 46

ECCS PREACS B 3.7.12 BASES REFERENCES 1. UFSAR, Section 9.4.

2. UFSAR, Section 15.4.

3. Regulatory Guide 1.52 (Rev. 2).

4. 10 CFR 50, Appendix A.

5. NUREG-0800, Rev. 2, July 1981.

6. UFSAR, Figure 15.4-110

====lj7. TSTF-52~ _: ] 1 = = = = = = = = = = =

North Anna Units 1 and 2 B 3.7.12-11 Revision 45