ML20097F385

Application for Amends to Licenses NPF-4 & NPF-7,revising Time Frames in TS 3.0.5 for Conducting Shutdown in Controlled & Orderly Manner for Consistency W/Time Frames in TS 3.0.3

ML20097F385
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
ML20097F388	List: ML20097F385 ML20097F391
References
92-368, NUDOCS 9206150274
Download: ML20097F385 (8)

Text

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VilcorNIA UI.ECTHIC AND POWEli CH)!!%NY Harnwoxu,Vannixir unues June 8, 1992 U.S. Nuclear Regulatory Commission Serial No. 92 368 Attention: Document Control Desk NAPS /JYR Washington, D.C. 20555 Docket Nos. 50 338 50 339 License Nos. NPF-4 NPF-7 Gentlemen:

VIRGlNIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER _ STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATION CHANGES Pursuant to 10 CFR 50.90, the Virginia Electric and Power Company requests amendments, in the form of changes to the Technical 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 time frames in Technical Specification 3.0.5 for conducting a shutdown in a controlled and iorderly manner to be consistent with the time frames in Technical Specification 3,0.3.

- A discussion of the proposed changes is provided in Attachment 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 defincd 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, L

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W. L. Stewart

-Senior Vice President - Nuclear s,\\\\g p$615027492o60sADOCK 05ooo338 I%

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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 cc:

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 i;

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i COMMONWEALTH OF VIRGINIA )

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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.

H9 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 day of

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Discussion of Proposed Changes North Anna Units 1 and 2 N.

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DISCUSSION OF PROPOSED CHANGE Introduction The proposed change revises Technical Specification 3.0.5 completion times to permit a shutdown to proceed in a controlled and orderly manner that is within the maximum cooldown rate and within the cooidown capabilities of the unit assuming only the minimum required equipment is operable.

Technical Specification 3.0.5 delineates additional conditions that must be satisfied to permit operation to continue when a normal or emergency power source is not operable. It specifically prohibits operation when one division is inoperable because its normal or emergency power source is inoperable, and a system, subsystem, train, component, or device in another division are inoperable for another reason.

Background

An NRC letter to All Power Reactor Licensees, dated April 10, 1980, requested licensees to submit proposed Technical Specifications 3.0.3 and 3.0.5. The NRC letter contained model Technical Specifications. Model Technical Specifications 3.0.3 and 3.0.5 were formulated to ensure tnat no set of equipment outages would be allowed to persist that would result in the facility being in an unprotected condition. The model Technical Specifications 3.0.3 and 3.0.5 contained the same time fremes to reach hot standby, hot shutdown, and cold shutdown.

License amendment number 19 for Unit 1 and the original operating license for Unit 2 issued Technical Specifications 3.0.3 and 3.0.5 consistent with the April 10,1980, NRC letter. Hcwever,. Technical Specification 3.0.3 was revised in license amendment

-numbers 62 and 46 for Units 1 and 2, respectively License amendment numbers 62 and 46 allowed one hour to initiate actions and changed the time frames to reach hot standby, hot shutdown, and cold shutdown for Technical Specification 3.0.3. These license amendments were _ consistent with NUREG 0452, Revision 4, " Standard Technical Specifications for Westinghouse Pressurized Water Reactors." However, NUREG-0452 does not include Technical Specification 3.0.5. As a result, we did not evaluate or request a change to Technical Specification 3.0.5 at that time.

As a result of issuance of license amendment numbers 62 and 46, the time frames for Technical Specifications 3.0.3 and 3.0.5 became inconsistent. The changes proposed herein correct this inconsistency and mee+. the intent of tw April 10,1980, NRC letter, while still maintaining consistency with NUREG 0452.

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i Technical Specification Change

- General The technical specification change described herein applies to North Anna Units 1 and 2.

The - provisions of Technical Specification 3.0.5 permit the action statements asociated with individual systems, subsystems, trains, components, or devices to be consistent with the action statements of the associated electrical power source. It allows operation to be governed by the *ime limits of the action statement associated cy power sourca, not the with the Technical Specification for the normal or emere individual action statements for each system, subsystem, cin, component, or device that is determined to be inoperable solely because of the inoperability of its normal or emergency power source.

For example, Technical Specification 3.8.1.1 requires that two emergency diesel generators be operable. The stico statement provides for a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> outage time when one emergency diesel generator is not operable. If the definition of operable was applied without consideration of Technical Specification 3.0.5, all systems, subsystems, trains, components, and devices supplied by the inoperable emergency power source would also be inoperable. This would dictate invoking the applicable action statement. However, the provisions of Techiilcal Specification 3.0.5 permit continued operation consistent with the action statement for the inoperable emergency diesel generator, provided the other specified conditions are satisfied. In this case, the corresponding normal power source must be operable, and all redundant systems, subsystems, trains, components, and devices must be operable, or otherwise satisfy Technical Specification 3.0.5 (i.e., remain capable of performing their design function and have at least one normal or emergency power source op9rable). If the conditions are not satisfied, action is required in accordance with Technical Specification 3.0.5.

Technical Specification 3.0.5 currently states the following:

"When a system, subsystem, train. component or device is determined to be inoperable solely because its emergency power source is inoperab's, or solely because its normal power source is inoperable, it may be considered OPERABLE for thn purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE: and (2) all of its redundant system (s), subsystem (s), train (s), component (s) and device (s) are OPERABLE, or 13ewise satisfy the requirements of this specification. unless both conditions (1) and (2) are satisfied, the unit shall be placed in at least HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, in a! least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least 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 />. This Specification is not applicable in MODES s or 6."

This requires that the unit be placed in hot standby within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in 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 /> if the conditions stated in the Technical Specification are not met.

4 Technical Specification 3.0.5 is not applicable in modes 5 or 6.

Therefore, the indlyidual action statements for each applicable Technical Specification must be adhered to when in these modes.

Technical Soecification 3.0.5 The proposed change will modify Technical Specification 3.0.5 such that it includes the following actions if the conditions stated in the applicable Technical Specification are not met:

" within one hour ACTION sha!! be initiated to place the unit in a MODE in which the Specification doos not apply by placing it, as applicable, in:

1.

At least HOT STANDcY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 2.

At least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and 3.

At least COLD SHUTDOWN within the fehwing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Exceptions to these requirements are stated in the individual Specifications."

Therefore, the revised Technical Specification 3.0.5 will read as follows:

"When a system, subsystem, train, component or device is dotermined to be inoperable solely because its amorgency power tource is inoperable, or se:ely because its normal power source is inoparable, it may be considered OPERABLE for the purpose ci satisfying the requirements of its applicable Limiting Condition for Operation, providod:

1, Ms corresponding normal or emergency power source lu OPERABLE, and

2. All of its redundant system (s), subsystom(s), trein(s), component (s) and dovice(s) ere OPERABLE, or likewise satisfy the requirements of this Spoedication.

Unless both conditions 1, end 2. above are satisfied, within one hout ACTION shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it, as applicable, in:

1 At least HOT STANDBY within E hours, 2.

At least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and r

3, At least COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Exceptions to these requ!roments are stated in the individual Specifications.

This Specification is not applicable in Modes 5 or 6."

Format changes have been incorporated in the proposed change strictly for editorial purposes.

The purpose of the revised section of Technical Specification 3.0.5 is to delineate the time limits for placing the unit in a safe shutdown mode. One hour is permitted under the proposed change to orepare for an orderly shutdown before initiating a change in plant operations. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid.

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The completion times specified to reach lower modes of operation permit a shutdown to proceed in a controlled and orderly manner that is within the maximum coolqown rate and within the shutdown capabilities of the unit assuming only the minimum required equipment is operable. This reduces thermal stresses on components of the primary coolant system and the potential for c plant upset that could challenge safety systems under conditions for which these time limits would apply.

The completion times proposed above to reach hot standby, hot shutdown, and cold shutdown for Technical Specification 3.0.5 are consistent with the completion times currently established in Technical Specification 1.0.3.

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