ML20097F344

Application for Amends to Licenses NPF-4 & NPF-7,changing TS to Permit Staggered Testing of Reactor Trip Sys Instrumentation & to Permit Up to 2 H to Test Certain ESFAS Instrumentation

ML20097F344
Person / Time
Site:	North Anna
Issue date:	06/08/1992
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20097F346	List: ML20097F344 ML20097F350
References
92-392, NUDOCS 9206150257
Download: ML20097F344 (7)

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a Ysito NIA I?titrTrilO AND I' owl lf COhil'ANY ltican>to w n Vinoix 4 unuoi June 8, 1992 U.S. Nuclear Regulatory Commission Serial No. 92 392 Attention: Document Control Desk NAPS /RMN Washington, D.C. 20555 Docket Nos. 50 338 50 339 License Nos. NPF 4 NPF 7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY RORTH ANNA POWER STATION UNITS 1 AND 2 EROPOSED TECHNICAL SPECIFICATION CHANGES Pursuant to 10 CFR 50.90, the Virginia Electric and Power Company requests amendments, in the form of changes to the Yechnical Specifications, to Operating License Numbers NPF 4 and NPF 7 for North Anna Power Station Units 1 and 2, respectively. The proposed change will revise the-current Technical Specifications to permit staggered testing of the Reactor Trip System instrumentatien and to permit up to two hours to test cortain Emergency Safeguards Feature Actuation System instrumentation. Some minor administrative changes are also included.

A discussion of the proposed changes is provided in Attach 1ent 1. The proposed changes are presented in Attachment 2 for Units 1 -and 2, respectively.

This request has been reviewed by the Station Nuclear Safety and Operating Committee and the Management Safety Review Committee, it has been determined that this request does 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 no signification hazards consideration is involved is presented in Attachment 3.

Should you have any questions or require additional information, please contact us at your earliest convenience, Very truly yours e Mf..

1 ,

W. L. Stewart j Senior Vice President - Nuclear 38- g p PDR

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Attachments

1. Discussion of Proposed Changes

2. Proposed Technical Specification Change for North Anna Units 1 and 2

3. 10 CFR 50.92 Significant Hazards Consideration ec: U.S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N.W.

Suite 2900 Atlanta, GA 30323 Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station Commissioner Department of Health Room 400 109 Governor Street Richmond, Virginia 23219

d COMMONWEALTHOFVIRGINIA )

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COUN1YOFHENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by W. L Stewart who is. Senior Vice Procldent - 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 doct. ment are true to the best of hic knowledge and belief.

Acknowledged before me this day of- . //A , - , 19 72.

My Commission Expires: fd/A o3 / , 19 3

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Notary Public W

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Discussion of Proposed Changes i

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a DISCUSSION OF PROPOSED CHANGES Introduction The proposed changes described herein are being made to Technical Specification 4.3.1.1.1, " Reactor Trip System Insrumentation," Table 4.31, item 19 and Technical Specification 3.3.2.1, " Engineered Safety Feature Actuation System (ESFAS) Instrumentation," Table 3.3 3, Action 20. Currently, Table 4.3-1, Itern 19 requires that the Safety injection Input from ESF logic function be testea on a monthly basis. The proposed change will add Notation 5 and increaue the surveillance interval from monthly (overy 31 days) to every 62 days on a staggered test basis. Table 3.3 3, Action 20 allows bypassing one channel for testing purposes for one hour. The proposed change willincrease the time that a channel may be bypassed for testing purposes from one to two hours.

The proposed changes also include administrative changes to the Technical Specifications. These changes serve to clarify the Technical Specification requirements and do not change the technical content.

Background

There are two trains of Reactor Trip System and ESFAS instrumentation. The two trains of instrumentation are verified operable by performing surveillance procedures PT-36.1 A and PT-36.1B,

• Solid State Protection System Test."

These tests place one train of the Solid State Protection System (SSPS) in bypass and test the inputs and outputs to ensure that the train is operable.

Specifically, the Safety injection input from ESF, Auxiliary Feedwater Pump Ctart Autonutic Actuation Logic and Steam Line isolation Automatic Actuation Logic functions are proven operable by those tests.

Technical Specification 3.3.1.1 requires that the Reactor Trip System instrumentation channels and interlocks of Table 3.31 be operable with response times as shown in Table 3.3 2. The Safety injection input from ESF function is part of the Reactor Trip System instrumentation.

Recently, we conducted a review to ensure that surveillance requirements are incorporated into appropriate surveillance test procedures. During this review, we determined that Technical Specification 4.3.1.1.1 requires testing both trains of Safety injection input from ESF logic each month. Since that time, both trains of SSPS have been tested each month in order to meet the surveillance requirement.

- _ _ - _ _ _ - _ _ _ - _ - -. __ ____ A

Technical Specification 3.3.2.1 requires that the ESFAS instrumentation channels shown in Table 3.3 3 are operable with the trip setpoints set ,

cons! stent w!th the values shown in the inp setpoint column of Table 3.3 4 and with response times as shown in Table 3.3 5. The Auxiliary Feedwater Pump Start Automatic Actuation Logic and the Steam Line isolation Automatic Actuation Logic functions are part of the ESFAS instrumentation. It was determined during a recent rev:ew that Table 3.3 3, Action 20 did not allow adequate time to perform the required monthly testing of either the Auxiliary Feedwater Pump Start Automatic Actuation Logic function for Units 1 and 2 or the Steam Line Isolation Automatic Actuation Logic function for Unit 2. (Table 3.3 3 does permit sufficient time (i.e., two hours) when testing the Steam Line Isolation Automatic Actuation Logic function for Unit 1, and therefore, no change is required.)

Technical Specification Changes General The Technical Specification char.ges described herein apply to North Anna Units 1 and 2, unless otherwise stated.

Technical Soecification 4.3.1.1 1. TableA.3-1. Item 19 This change will modify Technical Specification 4.3.1.1.1, Reactor Trip System Instrumentation, Table 4.31, item 19, Safety injection input from ESF, to increase the surveillance interval from monthly (every 31 days) to every 62 days on a staggered test basis. This is accomplished by adding Notation 5, which states "Each train or logic channel shall be tested at least every 62 days on a STAGGERED TEST BASIS," to item 19.

The change is consistent with the requirements for the rest of the SSPS and is more stringent than the requirements- of NUREG -- 0452, Standard Technical Specifications for Westinghouse Pressurized Water Reactors, Revision 4. Before the review indicated the need to perform testing on both trains each month, all testing for the SSPS was performed on a staggered test basis frequency. The frequency at which the SSPS is now being tested increases the possibility of incdvertent actuations and decreases the amount of time that both trains of SSPS are operable. Testing on a staggered test basis is edequate to ensure the continued reliability of the system, limit the possibility of inadvertent actuations, and maximize the arnount of time that both trains of SSPS are operable.

Technical Soecification .4.3.1.1.1. Table 4.31. Items 21 and 22 The word "and" has been changed to "&"in several places for consistency.

Technical Suecification 3.3.2.1. Table 3.3 3. Action 17 The statement consists of two independent statements that have been spliced together with a comma. This change will substitute a period for the comma and capitalize the next word.

Iechnical Soecification 3 3 2.1 Table 3.3 3. Action 19 The word " requirements" is changed to singular to agree with the verb.

Technical Soecification 3.3.2.1, Table 3.3 3. Action 20 This change will modify Technical Specification 3.3.2.1, Table 3.3 3, Action 20, to allow a channel to be bypassed for up to two hours for testing purposes.

The monthly channel functional test requirement is met by implementing surveillance procedures PT 36.1 A and PT-36.18, Solid State Protection System Test. These tests place one train of SSPS in bypass and test the different inputs and outputs to ensure that the system is operable. During the time that the inputs and outputs are bypassed, the channel is inoperable. One of the actions that must be entered during this time frame IF Action 20. Action 20 states that "With the number of OPERABLE Channels one less than the Total Number of Channels, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; however, one channel may be bypassed for up to 1 nour for surveillance testing per Technical Specification 4.3.2.1.1 provided the other channel is OPERABLE." However, the entire channel functional test takes between one and two hours to complete.

The proposed change is consistent with Table 3.3 3, Action 22, of NUREG 0452, Standard Technical Specifications for Westinghouse Pressurized Water Reacters, Revision 4. Action 22 allows the Auxiliary Feedwater Pump Start Automatic Actuation Logic and the Steam Line Isolation Automatic Actuation Logic functions to be bypassed for up to two hours when testing in accordance with Technical Specification 4.3.2.1.1. In addition, the NRC has previously issued guidance that it is not desired to knowingly perform maintenance or a surveillance wh!ch will require entoring an action statement that would cause a unit to shut down.

The change also converts "WITHIN" to lower case letters for Unit 1 only because it is not a defined term.

Technical Soecification 3.3.2.1. Table 3.3 3. Action 21 This change willinsert "the next" after

• HOT STANDBY within* to clarify the fact that the six hours to HOT STANDBY starts after the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the channel ends. This does not change the intent of the requirement.