ML20072J208
| ML20072J208 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/24/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20072J194 | List: |
| References | |
| GL-93-08, GL-93-8, NUDOCS 9408260248 | |
| Download: ML20072J208 (4) | |
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WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N05. 187 AND 168 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
By letter dated June 9,1994, 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).
The proposed changes would relocate the TS tables of the response time limits for the Reactor Trip System (RTS) and the Engineered Safety Feature Actuation System (ESFAS). The licensee's proposed changes are identified in NRC Generic Letter (GL) 93-08.
2.0 DISCUSSION The RTS and the ESFAS provide the signals needed to actuate the safety equipment necessary to mitigate accidents and transients.
The measurement of response times of these instruments provides assurance that the action functions associated with each channel are completed within the time limit assumed in the accident analyses.
On December 29, 1993, the NRC issued GL 93-08, which provides guidance for relocating the RTS and ESFAS instrument response time limit tables to station-controlled documents as a line-item TS improvement.
Relocating these tables to station-controlled documents will allow changes to these tables to be controlled in accordance with the provisions of 10 CFR 50.59 and the administrative controls for procedure changes as established in TS Section 6.8
" Procedures and Programs" without the need to process a license amendment request.
Relocating the RTS and ESFAS instrument response time limit tables to station-controlled documents will not affect the safety function in that the operability and surveillance requirements for these instruments specified.in the TS will not change.
TS surveillance review for RTS and ESFAS instruments was completed in August 1993. This review verified that all surveillance requirements are satisfied by current plant procedures.
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3.0 Specific Chances These TS changes apply to both NA-l&2.
o TS 3.3.1.1, Limiting Condition for Operation.
Delete "with RESPONSE TIMES as shown in Table 3.3-2."
o Surveillance Requirement 4.3.1.1.3.
After the first sentence, add the following as required by GL 93-08: " Neutron detectors are exempt from response time testing. Response of the neutron flux signal portion of the channel time shall be measured from the detector output or input of the first electronic component in the channel." Correct typographical error by changing " Table 3.3.1" to " Table 3.3-1" in the last sentence.
o Delete pages 3/4 3-10 and 3/4 3-11.
o TS 3.3.2.1, Limiting Condition for Operation.
Delete "and with RESPONSE TIMES as shown in Table 3.3-5."
o For NA-1 delete pages 3/4 3-27 through 3/4 3-30.
o for NA-2 delete pages 3/4 3-29 through 3/4 3-32.
The response time limits specified in the TS are implemented by plant procedures and upon approval of amendments they will be incorporated into the next revision of the North Anna Power Station Technical Requirements Manual (NAPSTRM).
4.0 NAPSTRM Although the GL describes relocating the affected tables to the Updated Final Safety-Analysis Report (UFSAR), the licensee alternately proposed to relocate them to a separate station-controlled document, the NAPSTRM. The NAPSTRM was developed as part of the NA-1&2 effort to consolidate the references that are used by station support and operations personnel in determining compliance with the various requirements that govern the safe operation of NA-l&2.
Many of these requirements were formally contained in TS and, over the past several years, have been authorized for removal from TS by the NRC through various license amendments.
In the past these requirements were relocated to the UFSAR or various plant administrative procedures. This previous relocation effort has proven to be inefficient in that numerous documents must be referenced by station support and operations personnel to determine the various requirements. This research process is time consuming.and requires local storage facilities for numerous documents.
The NAPSTRM was developed in response to this concern. The initial development and implementation of the NAPSTRM has been well received by station personnel. The NAPSTRM, when fully developed, along with the TS, will 1
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provide an easy reference for plant support and operations personnel to use in order to make technically accurate decisions concerning the various requirements that govern the safe operation of the station.
Changes to the NAPSTRM, including the addition or relocation of technical requirements, are in accordance with the provisions of Section 6.8 " Procedures and Programs" of the Administrative Controls section of the TS.
In addition, all changes, additions, or relocation of technical requirements must satisfy
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the criteria established in 10 CFR 50.59 " Changes, Tests, and Experiments."
Subsequent changes to these limits in the NAPSTRM will be submitted to the NRC as part of the annual report required by 10 CFR 50.59 (b)(2). This report provides a summary description of the facility changes, tests and experiments, including a summary of the safety evaluations that were conducted during the past year.
5.0 EVALUATION The proposed changes to the RTS and ESFAS TS are consistent with the intent of GL 93-08, " Relocation of Technical Specification Tables of Instrument Response Time Limits," dated December 29, 1993. The proposed change will relocate the RTS and ESFAS response time limit tables to station-controlled documents. The surveillance and technical requirements of the RTS and ESFAS instrument response times will not be affected. Therefore, there is no effect on the ability of this instrumentation to perform its intended safety function. This relocation of the RTS and ESFAS response time limit tables to station-controlled documents has been examined and accepted by the NRC staff in GL 93-
- 08. Therefore, based on all of the above, the staff finds the proposed changes to be acceptable.
6.0 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.
7.0 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 (59 FR 37088). 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.
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8.0 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: August 24, 1994 s
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