ML20106J609

Proposed Tech Spec 3/4.4.7,Table 4.4-3,eliminating Requirement to Sample Chlorides & Fluorides When RCS Drained Below Reactor Pressure Vessel Nozzles & Internals &/Or Head in Place

ML20106J609
Person / Time
Site:	North Anna
Issue date:	02/11/1985
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20106J601	List: ML20106J599 ML20106J609
References
NUDOCS 8502190036
Download: ML20106J609 (4)

Text

4 . .wi . .5 p .-q.4 r -v~,... -4..+--2 s 3 g , , , 9 ,,,,,, ,, ,,, . , , __ , __

g 'M

• y

(. 4 - .I 'm

,f, _

• • . i 0

? g 8 ' l, 2 i . e-

'-t-'

• g .g g

N

'y- \

9 e l 4 1 5

i'.

4

j. -

(

J.

a 1

i I

1 .

4-i ATTACHMENT:1 s 3 I

f 4

PROPOSED TECHNICAL SPECIFICATION CHANGE

'I. I i

i i

1 1

s s t

I

,k J

4 L

d i,

4 1

1 0 fl PDR 1

. , , - _ . .-- - . - , . - ,-,,, .m,-,_--.,,_.-_,,,. ----- - ..._. ._.. ~ ,._,_.. . .-_._,._-,..~._. -,_-,.__..... ,

y .;,

TABLE ~4.4-3

' REACTOR COOLANT SYSTEMI i'

CHEMISTRY LIMITS SURVEILLANCE REQUIREMENTS.

- MINIMUM:-

' PARAMETER ANALYSIS FREQUENCIES

~

DISSOLVED OXYGEN

• At least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

- CHLORIDE ** At least once-per 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s-

FLUORIDE ** 'At-least'once'per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

• Not required.with T less than or equal to 250*F

avg i **Not. required when the Reactor Coolant System is'-drained below the reactor pressure vessel nozzle and the internals and/or head are in place.

S f 1

e d

4 1

i e

4 1

i NORTH ANNA - UNIT 2 3/4 4-21

, . - ,-- . - - , - , . - - . . - , . , . - . . , , , .. . . - , . , . - - , . . _ - . , , . . , - , -.-. ,,_, - , - , , . - - - , , , . ~ ,

'p, ATTACHMENT 2 DISCUSSION OF PROPOSED TECHNICAL SPECIFICATION CHANGE

y c . r> ; ,

DISCUSSION OF PROPOSED TECHNICAL SPECIFICATION CHANGE

' The proposed Technical Specification change reflects a revision to Technical

~

Specification 3/4.4.7, Table 4.4-3, for North Anna Unit 2,- to delete the requirement for sampling chlorides and fluorides when the reactor coolant system is drained below the reactor pressure vessel nozzle and the internals and/or head are-in= place.

_ Currently,' ' chlorides ~and fluorides in the reactor coolant system requir'e surveillance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. To perform refueling and maintenance activities, the reactor coolant system -is drained below the nozzle, the RHR system is drained and the upper internals are in place. To get the required chloride and fluoride samples for the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> analysis frequency, it would mean that there will be radiation exposure involved because an individual would have to go into the upper internals area (which currently has a 10 R radiation ~ field). Since the reactor coolant system and RHR _ system are drained, the inventory of chlorides and fluorides will not change. No makeup.

is planned to the reactor coolant system, and any makeup to the RCS could be detected.

Vepco will sample the chlorides and fluorides in the reactor coolant system prior to fully draining the system. Vepco will resume sampling the ' reactor coolant system for chlorf des and fluorides when the reactor coolant ' system is refilled, so that the chloride and fluoride inventory will be known and the Technical Specification required surveillance will~ be followed.

The probability of occurrence or the consequences of a malfunction of equipment important to safety and previously. evaluated in the FSAR is not increased because the chloride and fluoride inventory in the reactor coolant system will not change since the reactor culant system and RHR System are drained and the inventory was known at the last sample.

The possibility of a different type of accident or malfunction than was previously evaluated in the FSAR has not been created because the sampling of chlorides and fluorides will resume when the reactor coolant system is refflied to show that the samples are below their required limits.

The margin of safety as described in the BASES section of any part of the Technical Specifications is not rehced because sampling of chlorides and fluorides will resune when the reactor coolant system is refilled and the chloride and fluoride inventory was within specifications at the time of drain down. Additional make9p could be detected.

It has been determined that this change does not pose a significant hazards consideration. Example iv of examples of amendn.ents that are considered not likely to involve a significant hazards consideration states, "A relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet demonstrated.. This assumes that the operating restriction and the criteria to be applied to a request for relief have been established in a prior review and that it is justified in a satisfactory way that the criteria have been met."

The proposed change for Unit 2 was previously reviewed and appr)ved by the NRC ,

for Unit I as indicated in Amendment No. 41 to Facility Operating License NPF-4, dated August 4, 1982. The NRC's approval of the Unit 1 amendment indicated that the proposed change did not pose an unreviewed safety question or a significant hazards consideration.

JHL/acm:m3/034

. .- .