ML20045G592

Application for Amends to Licenses NPF-4 & NPF-7,changing TS 3/4.6.1.2 by Removing Schedular Requirements for Type a Tests to Be Performed at 40 Plus or Minus 10 Month Intervals & Instead Ref Type a Testing,Per 10CF50,App J

ML20045G592
Person / Time
Site:	North Anna
Issue date:	07/02/1993
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20045G593	List: ML20045G592 ML20045G598
References
93-386, NUDOCS 9307140171
Download: ML20045G592 (8)

Text

. .

Ylif OINIA t$LECTitIC AND POWHH COMI'ANY N ICIDION D, VI H OINI A 20261 July 2, 1993 U.S. Nuclear Regulatory Commission Serial No.93-386 Attention: Document Control Desk NL&P/JBL R0 Washington, D.C. 20555 Docket Nos. 50-338-50-339 License Nos. NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE Pursuant to 10 CFR 50.90, the Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications, to Facility Operating License Numbers NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. The proposed changes would modify Technical Specification 3/4.6.1.2 by removing the schedular requirements for Type A tests to be performed specifically at 40i10 month intervals and instead reference Type A testing in accordance with Appendix J to 10 CFR Part 50. The proposed changes also include several editorial / administrative changes. Removal of the schedular requirements from the Technical Specifications will provide flexibility in scheduling of Type A tests without changing the intent of the regulatory requirement.

A discussion of the proposed Technical Specifications changes is provided in Attachment 1. The proposed Technical Specifications changes are provided in Attachment 2. It has been determined that the proposed Technical Specifications changes do not involve an unreviewed safety question as defined in 10 CFR 50.59 or a significant hazards consideration as defined in 10 CFR 50.92. The basis for our determination that the changes do not involve a significant hazards consideration is provided in Attachment 3. The proposed Technical Specifications changes have been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Management Safety Review Committee.

Should you have any questions or require additional information, please contact us.

Very truly yo0.rs, gyp i kCt; -

W. L. Stewart Senior Vice President - Nuclear Attachments 190007 t~

0k 0

9307140171 93o7o2

(

PDR P

ADOCK 0500o338 PDR (

T; -

\\

cc: U.S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N.W.

Suite 2000 Atlanta, Georgia 30323 Mr. D. R. Taylor NRC Resident inspector North Anna Power Station Commissioner Department of Health Room 400 109 Governor Street Richmond, Virginia 23219 m

k

t COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by W. L. Stewart who is Senior Vice President -

Nuclear, of Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this ['b day of (Mt//.1 .19h.

My Commission Expires: k [M4e 3 196 m

~

.l(Ie' ( f 1'Ad Notary P'ubfic l

(SEAL)

I

. l l

ATTACHMENT 1 DISCUSSION OF CHANGES VIRGINIA ELECTRIC AND POWER COMPANY 1

l l

I l

i

Discussion of Changes Type A Test Schedule

)

North Anna Power Station Units 1 and 2 Introduction Pursuant to 10 CFR 50.90, Virginia Electric and Power Company requests changes to Technical Specifications 3/4.6.1.2 for North Anna Power Station Units 1 and 2. The North Anna Technical Specifications currently require a set of three containment integrated leakage rate (Type A) tests be performed specifically at 4010 month intervals during each 10-year service period with the third test of each set performed during the shutdown for the 10-year plant inservice inspection. Appendix J to 10 CFR Part 50 requires that a Type A test of the containment be performed periodically.

These tests are required to be scheduled as a set of three tests, to be performed al aggroximatelv eaual intervals. during each 10-year service period with the third test of 1 each set to coincide with the shutdown for the 10-year plant inservice inspection.

While the North Anna Technical Specifications leakage rate testing requirements essentially duplicate the requirements in Appendix J, the Technical Specifications ,

additionally require the Type A test be performed at 40i10 month intervals. The Technical Specifications requirement to conduct Type A tests at 40i10 month intervals ,

is too restrictive. Therefore, Virginia Electric and Power Company proposes to revise the Technical Specifications for North Anna Units 1 and 2 to delete the_ detailed surveillance schedule for the Type A tests and instead reference performance of Type A testing in accordance with . Appendix J to 10 CFR 50. in addition, there are several editorial changes being made to this section of the Technical Specifications. .

Background i The Technical Specifications required schedule provides only a 20-month window for scheduling of Type A tests. This requirement is not appropriate for a facility like North .

Anna which is on an 18-month fuel cycle. An 18-month fuel cycle does not provide sufficient flexibility for three tests within a 10-year service, period when limited by the stipulation that the tests be performed at 40i10 months intervals.

During the first 10-year service period for each of the North Anna units, Technical Specifications change requests were submitted requesting approval to deviate from the Technical Specifications specified Type A test schedule. Each of these change requests proposed to alter the schedule by only a few months. However, since such a' change has been needed in the past and needed for the current 'and future service

. period, the Technical Specifications requirement is evidently too restrictive.

For 18 month fuel cycles, the . Type A tests must be conducted every other refueling outage to be within the 30- to 50-month range allowed by the Technical Specifications-for the first ar.d second test of the service period. But then, an extension is needed to make the third and last test coincide with the 10-year inservice inspection outage. ,

Therefore, Virginia Electric and Powor Company proposes to revise the Technical Specifications for North Anna Units 1 and 2 to refer to 10 CFR Part 50, Appendix J, l

I

Page 2 of 4 which requires only that the tests be conducted "at approximately equal intervals" during the 10-yaar service period with the third test being conducted during the inservice inspection outage. Typically, this would result in tests being conducted at intervals of 4-1/2 years,3 years, and 3 years over a 10-year period.

Specific Changes The specific changes to the North Anna Units 1 and 2 Technical Specifications are as follows:

Revise Surveillance Requirement 4.6.1.2.a to remove the specific requirement 4 that the Type A tests be performed at 40i10 months intervals with the third test of each set conducted during the shutdown for the 10-year plant inservice inspection. The revised requirement will read:

" Type A (Overall Integrated Containment Leakage Rate) tests shall be conducted in accordance with the requirements specified in Appendix J to 10 CFR 50."

Delete Surveillance Requirements 4.6.1.2.b and 4.6.1.2.c. These Type A test requirements also are specified in Appendix J to 10 CFR 50 and need not be reiterated in the Technical Specifications.

Renumber the remaining Surveillance Requirements for continuity. This is an administrative change. Consistent with this renumbering, the reference in Specification 4.6.1.1.c is revised from " Specification 4.6.1.2.d" to " Specification 4.6.1.2. b."

Revise the format of Specification 3.6.1.2.a to eliminate the single subsubparagraph and delete the word "or" at the end of the statement. Both the subsubparagraph format and the conjunction word are unnecessary. The original format was taken from the NRC's Standard Technical Specifications (STS) for Westinghouse Pressurized Water Reactors. The STS had two options under Specification 3.6.1.2.a, however, North Anna Units 1 and 2 were not licensed for the second option. This proposed format change does not change the intent of the Specification. This is an editorial change.

Revise Specification 3.6.1.2.a to add the phrase "the calculated peak containment pressure" as a description in front of the term "Pa." The addition of this phrase provides clarification and does not change the intent of the Specification. This is an editorial change.

Remove the footnotes on the bottom of Technical Specifications Page 3/4 6-2 for both units. Removing these special requirement footnotes does not constitute a change to the Specification. The special requirements were applicable to a specific cycle or outage. The special requirements have been completed and the footnotes are no longer required. This is an administrative change.

4 .

Page 3 of 4  !

For Unit 1 only, revise the Action Statement for Specification 3.6.1.2 to be worded exactly like the Unit 2 Actio1 Statement. This proposed change does not change the intent of the Action Statement. This is an editorial change.

Throughout Specification 3/4.6.1.2, each of the symbols "s" and "2" has been replaced with the appropriate phrases "less than or equal to" and " greater than or equal to," respectfully. This effects the Unit 1 Technical Specifications only.

This is an editorial change.

Safety Significance Satisfactory leakage rate test results are a requirement for the establishment of containment operability. Neither the general frequency nor the required number of Type A tests are changed. In addition, the maximum allowable leakage rate at the calculated peak containment pressure has not been changed. Only the detailed schedule for completion of each test has been removed to provide more flexibility in scheduling of tests.

Based upon the following justification, operation of the North Anna Power Station having removed the specific 40110 month test interval for performance of Type A testing and having made the associated administrative / editorial changes would not involve an unreviewed safety question.

(1) The proposed changes would not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed change to the schedule provides only flexibility in meeting the same requirement for three tests in ten years. The additional flexibility is needed for 18-month fuel cycles.

The test type and test method used are not changed.

Type A, B, and C tests will continue to be performed in accordance with Appendix J to 10 CFR 50. The Type A test acceptance criteria have not changed and the combined leakage of penetrations subject to Types B and C tests will continue to be maintained within the required limits.

(2) The proposed changes would not create the possibility of a new or different type of accident from any accident previously evaluated. The proposed change to the schedule only provides flexibility in meeting the same requirement for three tests in ten years. The testing type and bases are not changed.

Therefore, operation of the unit with this more flexible test schedule will not result in an accident previously not analyzed in the UFSAR. The proposed changes do not impact the design basis of the containment and do not modify the response of the containment during a design basis accident.

(3) The proposed changes would not involve a reduction in a margin of safety. The proposed changes to the schedule only provides flexibility in meeting the same requirement for three tests in ten years. These proposed changes do not affect or change any limiting conditions for operation (LCO) or any other surveillance requirements in the Technical Specifications and the Basis for the surveillance

Page 4 of 4 l

requirement remains unchanged. The testing method, acceptance criteria, and bases are not changed. The Technical Specifications continue to require testing l that is consistent with the requirements of Appendix J to 10 CFR 50. i Based on the above evaluation, removing the specific schedule for Type A tests and making the other administrative / editorial changes to the Technical Specifications will not adversely affect the safe operation of the plant. Therefore, this regulatory requirement reduction for North Anna Units 1 and 2 does not result in an unreviewed-safety question as defined in the criteria of 10 CFR 50.59.

l i

i I

l l

l j