ML20070N149
| ML20070N149 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/22/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20070N147 | List: |
| References | |
| GL-91-08, GL-91-8, NUDOCS 9405050131 | |
| Download: ML20070N149 (8) | |
Text
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E UNITED STATES l'
ii NUCLEAR REGULATORY COMMISSION
\\.....,8 WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.181 AND 162 TO FACILITY OPERATING LICENSE NOS. NPF-4 AND NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY OLD DOMINION ELECTRIC COOPERATIVE NORTH ANNA POWER STATION. UNITS N0. 1 AND NO. 2 DOCKET NOS. 50-338 AND 50-339
1.0 INTRODUCTION
l By letter dated October 8, 1993, the Virginia Electric and Power Company (the licensee) proposed changes to the Technical Specifications (TS) for the North Anna Power Station, Units No. I and No. 2 (NA-l&2).
Specifically, the proposed changes would delete tables listing certain components from the NA-l&2 TS and relocate these lists to plant procedures in accordance with the guidance provided in the Nuclear Regulatory Commission (NRC) Generic Letter (GL) 91-08, " Removal of Component Lists from Technical Specifications."
The lists affected by this TS change request include NA-l&2 Containment Isolation Valves (Table 3.6-1), NA-2 Containment Penetration Conductor. Overcurrent Protective Devices (Table 3.8-1), NA-2 Motoc-Operated Valves Thermal Overload Protection and/or Bypass Devices (Table 3.8-2), and NA-2 Normally De-energized Power Circuits (Table 3.8-3).
By relocating these lists to plant procedures, any identified discrepancies can be updated in a timely manner without prior NRC approval.
The Limiting Conditions for Operation (LCO), the Action Statements, and the Surveillance Requirements would still apply to all the components in these lists.
Also included in the proposed changes are administrative changes which are j
made to enhance the accuracy and clarity of the NA-l&2 TS.
2.0 DISCUSSION
GL 91-08, dated May 6, 1991, introduced an alternative to identifying every component by its plant identification number as it is currently listed in the l
i tables of TS components.
GL 91-08 provided the guidance and recommended wording for incorporation of TS component lists into plant procedures that are subject to the change control provisions for plant procedures in the administrative controls section of the TS.
By relocating the component lists associated with the subject TS change request into plant procedures, the administrative change control provisions of the TS provide an adequate means to control future changes to these lists.
This can be accomplished without 1
the requirement for a change to the TS, as is required to update component 9405050131 940422 PDR ADOCK 05000338 P
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lists in TS tables.
Relocation of component lists affected by this TS change from the TS to plant procedures will not alter the existing TS LCOs, Action Statements, or Surveillance Requirements for the affected components.
TS Index Page IX (NA-1) and-VIII (NA-2) 3/4.8.2 "0NSITE POWER DISTRIBUTION SYSTEMS" would be revised to reflect TS Amendment #155 for NA-1 and #137 for NA-2.
These amendments were issued on April 21, 1992 and revised the A.".
and D.C. Distribution TS requirements.
The index was not changed due to an oversight. Also, TS Index Page IX for NA-1 and NA-2 3/4.9.8 " RESIDUAL HEAL REMOVAL AND COOLANT CIRCULATION" would be revised to reflect TS Amendment #137 for NA-1 and #120 for NA-2.
These amendments were issued on August 27, 1990, 1
and revised the Residual Heat Removal and Coolant Circulation TS requirements.
The index was not changed due to an oversight. Additionally, TS Index Page IX for NA-2 and NA-2 3/4.9.10 " WATER LEVEL - REACTOR VESSEL" would be revised to reflect TS Amendment #115 for NA-1 and #98 for NA-2.
These amendments were issued on February 15, 1989, and revised the Reactor Vessel water level TS requirements. The index was not changed due to an oversight.
Finally, TS Index Page VIII 3/4.8.2 "0NSITE POWER DISTRIBUTION SYSTEMS" for NA-2 would be revised to reflect the actual plant configuration.
The motor-operated valves listed in TS 3.8.2.6 " MOTOR OPERATED VALVES THERMAL OVERLOAD PROTECTION AND/0R BYPASS DEVICES" do not have and are not required to have bypass devices installed.
TS Definitions for " CONTAINMENT INTEGRITY" for NA-l&2 would be revised in accordance with GL 91-08.
Specifically, the reference to valves listed in Table 3.6-1 of Specification 3.6.3.1 would be replaced with the phrase "for valves that are open under administrative control as permitted by Specification 3.6.3.1."
TS Surveillance Requirement 4.6.1.1.a " CONTAINMENT INTEGRITY" for NA-l&2 would be revised in accordance with GL 91-08.
Specifically, the reference to valves listed in Table 3.6-1 of Specification 3.6.3.1 would be replaced with the phrase "for valves that are open under administrative control as permitted by Specification 3.6.3.1."
TS 3.6.3.1 " CONTAINMENT ISOLATION VALVES" for NA-l&2 would be revised in accordance with GL 91-08.
Specifically, references to Table 3.6-1 would be deleted, a note indicating that "the provisions of Specification 3.0.4 do not apply" would be added, and a note stating that " lot.ked or sealed closed valves may be opened on an intermittent basis under administrative control" is added to Specification 3/4.6.3.
In addition, NA-1 Surveillance Requirements 4.6.3.1.1.a and 4.6.3.1.2.d would be revised to delete the "< and 2" symbols and replaced with "less than" and "is greater than or equal to."
Both Unit 1 and Unit 2 Surveillance Requirement 4.6.3.1.1.b deletes "above" for clarity as the "above" test is only for weight or spring-loaded check valves.
TS CONTAINMENT SYSTEMS BASES 3/4.6.3 for NA-l&2 would be revised in accordance with GL 91-08.
Specifically, the following paragraph would be added to the appropriate bases sections: "The opening of locked or sealed closed containment isolation valves on an intermittent basis under administrative
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3 control includes the following considerations:.(1) stationing an operator, who is in constant communication with control room, at the valve controls, and (2) instructing this operator to close these valves in an accident situation, and (3) assuring that environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside the containment."
1 TS 3.8.2.5 " CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES" for NA-2 would be revised in accordance with GL 91-08. Specifically, LC0 3.8.2.5 would be replaced with the LC0 statements " Primary and backup' containment penetration conductor overcurrent protective devices associated with each containment electrical penetration circuit shall be OPERABLE.
The scope of these protective devices excludes those circuits for which credible fault currents would not exceed the electrical penetration design rating," and both the Action Statement for Specification 3.8.2.5 and Surveillance Requirement 4.8.2.5.a.l(b) are revised to delete references to Table 3.8-1.
TS 3.8.2.6 " MOTOR OPERATED VALVES THERMAL OVERLOAD PROTECTION AND/0R BYPASS DEVICES" for NA-2 would be revised in accordance with GL 91-08 to delete references to Table 3.8.2.
In addition, all references to the bypass devices would be deleted since none of the motor-operated valves listed in the current Table 3.8-2 are equipped with bypass devices. Deleting the reference to the bypass devices results in deleting Surveillance Requirement 4.8.2.6.a which is not required unless the bypass devices are installed.
TS 3.8.2.7 "NORMALLY DE-ENERGIZED POWER CIRCUITS" for NA-2 would be revised to delete Table 3.8-3 and references to that table in the LCO, Action, and Surveillance Requirements.
In addition, the statement "when operating in Modes 1-4" would be deleted from Surveillance Requirement 4.8.2.7 as the Modes requiring the surveillance are already specified in the Applicability statement. This TS was added to NA-2 by Amendment #21, dated May 3, 1982, to list those loads whose electrical containment penetrations do not have secondary protection devices and could have creditable fault currents that could exceed the electrical penetration design rating. Although not listed in GL 91-08, this component list meets the intent of the GL for those lists that could be relocated to plant procedures.
3.0 TS CHANGES:
The proposed TS change would relocate the lists of containment isolation valves for NA-l&2, NA-2 containment penetration conductor overcurrent protective devices, NA-2 motor-operated valves (MOVs) thermal overload devices, and NA-2 normally deenergized loads from the TS to plant procedures which are controlled in accordance with the provisions of the administrative controls section of the applicable TS. Associated TS would be modified in accordance with GL 91-08, and administrative changes are made to enhance clarity and accuracy.
Specifically, the NA-l&2 TS are revised as follows:
o NA-1 TS Index Page IX for Section 3/4.8.2 would be modified to delete subsections "A.C. Distribution - Shutdown" and "D.C.
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4 Distribution - Shutdown" and replace with subsection "A.C. and D.C.
Distribution - Shutdown" on page 3/4 8-7.
o NA-l&2 TS Index Page IX for Section 3/4.9.8 would be modified to add'
"(RHR)" after RESIDUAL HEAT REMOVAL and change the title of the two subsections to " Normal Water Level" and " Low Water Levels."
o NA-1&2 TS Index Page IX for Section 3/4.9.10 would be modified to add the two subsections " Fuel Assemblies" and " Control Rods."
o NA-2 TS Index Page VIII for Section 3/4.8.2 would be modified to delete subsections "A.C. Distribution - Shutdown" and D.C.
Distribution - Shutdown" and replace with subsection "A.C. and D.C.
Distribution - Shutdown" on page 3/4 8-12.
The phrase "and/or Bypass" associated with " Motor Operated Valves Thermal Overload Protection Devices" would also be deleted.
o NA-l&2 Definition Page 1-2 item 1.6.1.b " CONTAINMENT INTEGRITY" would be modified to delete "except as provided in Table 3.6-1 of Specification 3.6.3.1" and add "except for valves that are open under administrative control as permitted by Specification 3.6.3.1."
o NA-l&2 TS Surveillance Requirement 4.6.1.1.a "CONTAINL !I INTEGRITY" would be modified to delete "except as provided in Table 3.6-1 of Specification 3.6.3.1" and add "except for valves that are open under administrative control as permitted by Specification 3.6.3.1."
o NA-l&2 TS Limiting Condition for Operation 3.6.3.1 " CONTAINMENT ISOLATION VALVES" would be modified to delete "The containment isolation valves specified in Table 3.6-1 shall be OPERABLE with isolation times as shown in Table 3.6.1" and add "Each containment isolation valve shall be OPERABLE.*"
o NA-l&2 TS Action Statement for LC0 3.6.3.1 " CONTAINMENT ISOLATION VALVES" would be modified to replace "With one or more of the isolation valve (s) specified in Table 3.6-1 inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and either:" with the phrase "With one or more of the isolation valves inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and:" The sentence "The provisions of Specification 3.0.4 do not apply." would be also added at the end of the TS action statements.
o NA-l&2 TS Surveillance Requirement 4.6.3.1.1 " CONTAINMENT ISOLATION VALVES" would be modified to replace "The isolation valves specified in _ Table 3.6.1 shall be demonstrated OPERABLE:" with the sentence "Each containment isolation valve shall be demonstrated OPERABLE:."
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o NA-1.TS Surveillance Requirement 4.6.3.1.1.a " CONTAINMENT ISOLATION i
VALVES" would be modified to delete the "<" symbol and replace that symbol vH th. the phrase "less than." The "1" symbol would be replaced with the phrase "is greater than or equal to."
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o In NA-1&2 TS Surveillance Requirement 4.6.3.1.1. " CONTAINMENT ISOLATION VALVES," the note "* Locked or sealed closed valves may be cpened on an intermittent basis under administrative control" would be added at the bottom of page 3/4 6-15 and page 3/4 6-14, respectively.
1 o
In NA-l&2 TS Surveillance Requirement 4.6.3.1.1.b " CONTAINMENT ISOLATION VALVES," the word "above" would be deleted.
o In NA-1&2 TS Surveillance Requirement 4.6.3.1.2 " CONTAINMENT ISOLATION VALVES," the phrase "specified in Table 3.6-1" would be deleted.
o In NA-1 Surveillance Requirement 4.6.3.1.2.d " CONTAINMENT ISOLATION VALVES," the "<" symbol would be replaced with the phrase "less than," and the "1" symbol would be replaced with the phrase "is greater than or equal to."
o In NA-1&2 TS Surveillance Requirement 4.6.3.1.3 " CONTAINMENT ISOLATION VALVES," the phrase "of Table 3.6-1" would be deleted.
o In NA-l&2 TS 3/4.6.3.1 " CONTAINMENT ISOLATION VALVES," pages 3/4 6-17 through 3/4 6-32 and pages 3/4 6-16 through 3/4 6-31, respectively, (Table 3.6-1, list of Containment Isolation Valves) i i
would be deleted.
o NA-1&2 TS Bases Section 3/4.6.3 " CONTAINMENT ISOLATION VALVES" would
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be revised by adding the paragraph "The opening of locked or sealed closed containment isolation valves on an intermittent basis under 4
administrative control includes the following considerations: (1) stationing an operator, who is in constant communication with control room, at the valvc controls, and (2) instructing this operator to close these valves in an accident situation, and (3) assuring that environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside the containment."
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NA-2 LC0 3.8.2.5 " CONTAINMENT PENETRATION CONDUCTOR OVERCURRENi i
PROTECTIVE DEVICES" would be revised by replacing the sentence "All containment penetration conductor overcurrent protective devices shown in Table 3.8-1 shall be OPERABLE" with " Primary and backup containment penetration conductor overcurrent protective devices 1
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4 6
associated with each containment electrical penetration circuit j
shall be OPERABLE.
The scope of these protective devices excludes 1
those circuits for which cre' : table fault currents would not exceed the electrical penetration casign rating."
o NA-2 Action Statement for LC0 3.8.2.5 " CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES" would be revised by deleting the phrase "shown in Table 3.8-1."
o NA-2 Surveillance Requirement 4.8.2.5 " CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES" would be revised by deleting the phrase "shown in Table 3.8-1."
o NA-2 TS Surveillance Requirement 4.8.2.5.1.b " CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES" would be revised by deleting the phrase "and as specified in Table 3.8-1."
o NA-2 TS 3/4.8.2.5 " CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES" would be revised by deleting pages 3/4 8-18 through 3/4 8-20 (Table 3.8-1, list of Containment Penetration Conductor Overcurrent Protective Devices).
o NA-2 3/4.8.2.6 " MOTOR OPERATED VALVES THERMAL OVERLOAD PROTECTION AND/0R BYPASS DEVICES" would be revised by deleting the phrase "AND/0R BYPASS" at the top of page 3/4 8-21.
o NA-2 TS LC0 3.8.2.6 " MOTOR OPERATED VALVES TliERMAL OVERLOAD PROTECTION AND/0R BYPASS DEVICES" would be revised by replacing the sentence "The thermal overload protection and/or bypa::s devices, integral with the motor starter, of each valve listed in Table 3.8.2 i
shall be OPERAP'.E" with "The thermal overload protection devices,
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intagral wit?
"e motor starter, of each valve used in safety systems shal 0PERABLE."
o NA-2 TS Actiu natement for LC0 3.8.2.6 "M0 TOR OPERATED VALVES THERMAL OVERLOAD PROTECTION AND/0R BYPASS DEVICES" would be revised by deleting the phrase "and/or bypass devices."
o NA-2 Surveillance Requirement 4.8.2.6 "M0 TOR OPERATED VALVES THERMAL OVERLOAD PROTECTION AND/0R BYPASS DEVICES" would be revised to delete the requirement for proving the operability of (non-existent) bypass devices and replaced with "The above required thermal overload protection devices shall be demonstrated OPERABLE at least once per 18 months by the performance of a CHANNEL CALIBRATION of a representative sample of at least 25% of all thermal overload devices, such that each device is calibrated at least once per 6 years."
o NA-2 3/4.8.2.6 "M0 TOR OPERAfED VALVES THERMAL OVERLOAD PROTECTION AND/0R BYPASS DEVICES" would be revised by deleting pages 3/4 8-22
7 through 3/4 8-25 (Table 3.8-2, list of Motor-0perated Valves -
Thermal Overload Protection and/or Eiypass Devices).
o NA-2 TS LC0 3.8.2.7 "NORMALLY DE-ENERGIZED POWER CIRCUITS would be revised to replace the sentence "All circuits shown in Table 3.8.3 shall be de-energized:".with "All circuits that have containment penetrations and are not required during reactor operation shall be de-energized."
o NA-2 TS Action Statement for LC0 3.8.2.7 "NORMALLY DE-ENERGIZED POWER CIRCUITS" would be reworded to read "With one or more of the circuits described above energized, de-energize the circuit (s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
o NA-2 TS Surveillance Requirement 4.8.2.7 "NORMALLY DE-ENERLIZED POWER CIRCUITS"' would be reworded to read "At least once per 31 days, verify that all of the circuits described above are de-energized by noting the position of the appropriate circuit breakers."
o NA-2 TS 3.8.2.7 "NORMALLY DE-ENERGIZED POWER CIRCUITS" would be revised to delete page 3/4 8-27 (Table 3.8-3, list of Normally De-energized Power Circuits).
4.0 EVALUATION
The proposed TS change would relocate the lists of containment penetration conductor overcurrent protective devices (NA-1 TS 3.8.2.5, Table 3.8-1),
i safety-related MOV thermal overload devices (NA-2 TS 3.8.2.6, Table 3.8-2) and normally de-energized containment loads (NA-1 TS 3.8.2.7, Table 3.8-3) and containment isolation valves (NA-1&2 TS 3.6.3.1, Table 3.6-1) to plant procedures.
By relocating these lists to plant procedures any identified discrepancies can be updated in a timely manner without prior NRC approval
)
under the provisions of 10 CFR 50.59. The LCO, the Action Statements, and the Surveillance Requirements of the TS would still apply to the components in these tables. The difference would be that, rather than being specifically listed in TS tables, the lists of these components would be. identified and maintained in plant procedures in accordance with the administrative control section of the applicable TS. The staff has also concluded that 10 CFR 50.36 does not require inclusion of these components in the TS beum n within the operability determination for these component lists, the survelliance requirements still must be satisfied.
In addition, deleting the reference to the thermal overload bypass devices in NA-2 TS 3.8.2.6 reflects the actual plant configuration since none of the referenced M0Vs have or are required to have the bypass devices.
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8 These changes are consistent with the guidance provided in Generic Letter 93-08 and the TS requirement of 10 CFR 50.36. Therefore, the staff finds the proposed changes to be acceptable.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Virginia State official was notified of the proposed issuance of the amendment.
The State official had no comment.
6.0 ENVIRONMENTAL CONSIDERATION
These amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding (58 FR 57860). Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Leon B. Engle Date: April 22, 1994 w ;,
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