ML20127D384

Application for Amends to Licenses NPF-4 & NPF-7,deleting TS 6.8.4.c(vii) Re Program for Monitoring Secondary Water Chemistry to Inhibit SG Tube Degradation,Per EPRI Guidelines & NUREG-0452,Rev 4 on STS for Westinghouse PWRs

ML20127D384
Person / Time
Site:	North Anna
Issue date:	09/04/1992
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20127D388	List: ML20127D384 ML20127D389
References
RTR-NUREG-0452, RTR-NUREG-452 92-543, NUDOCS 9209150002
Download: ML20127D384 (7)

Text

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, VillOIN f A 15LECTit!C ANI) }'OWI:lt CO)ll%NY I! !rll M O N I), YlitOIN I A 2113 61 September 4, 1992 U.S. Nuclear Regulatory Commission Serial No.92-543 Attention: Document Control Desk NAPS /JHL/MAE: R2 Washington, D.C. 20555 Docket Nos. 50 338 50 339 License Nos. NPF 4 NPF 7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY RQRTH 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 changea will revise the current Technical Specifications pertaining to ine monitorin0 program for secondary water chemistry.

A discussion of the propos6d changes is provided in Attachment 1. The proposed changes are presented in Attachments 2 and 3 for Units 1 and 2, respectively.

This request has been reviewed by the Station Nuclear Safety and Opsrating 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 Attachtneni 4. The proposed Technical Specification changes are consistent with NUREG-0452, Revision 4, " Standard Technical Specifications for Wes'inghouse Pressurized Water Reactors."

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Should you have any questions or require additionalinformation, please contact us.

Very truly yours, h Of A rm p, W. L. Stewart Senior Vice President Nuclear Attachments t

9209130002 920904 3 PDR ADOCK 05o00338 P(yV ' l P PDR g

cc: U.S. Nuclear Hogulatory Commission Region ll 101 Marietta Streat, N.W.

Suite 2900 Atlanta, Georgia 30323 Mr. M. S. Lessor NRC Sonior Resident inapoctor North Anna Power Station Commissioner Department of Health Room 400 109 Governor Street -

Richmond, Virginia 23219 4

1 h

i COMMONWEALTH OF VIRGINIA )

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COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the Coun'y and Commonwealth aforesaid, today by J. P. O'Hanlon, who is Vics President - Nuclear Operations, for W. L. Stewart who is Senior Vice President Nuclear, of Virginia Electric and Power Compar.y. He is duly authorized to execute and file the forogoing 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 w ndmh o,192 My Commission Expires: (llap .3 / .199I, d

E Y kh90 Notary Public _

(SEAL) 4

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ATTACHMENT 1 DISCUSSION OF- CHANGES

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.4 DlEQQSSION Of_ CHANGES INTRODUOTIOH -

Tee.hnical Specification 6.8.4.c cpecilie n program for monitonng secondary water chemistry to Mibit steam generator tube degradation. Specifically, Technical

" Scocification 6 tl.4.c(vii) requires moneang the condensate at tha d;ccharge of the g < *densate pumps for evidence cf coadenser inteakage. In addition, Technical s cificailon S.8.4.c(vii) requhes a leak to be repaired, plu0ged, or isolated within dy six (96) hours after leakage confirmatico.

.i.e propaseo y,anges delete Technical Specification 6.8.4.c(vii) In addition, Technical

'" Specification G 8.4.c(lii) is modified to reflect the deletion of Technical Specification i'A.c(vli). Editorial changes are proposed to Technical Specifications 6.8.4.c(v) and d.4.c(vi).

The Milicailon of Technical Specification G.8.4.c(iii) will continue to eu - lng l the ;ensate at the discharge of tne condensate pumps for evic' ser p inly ae. The time frames for the repair of condenser inleakage v sntrolled in accordance with station administrative procedures which hcve ir.ct. .arated industry guidance for action levels and acceptabic time frans Tho soposed changes are consistent wib. tn MM.) Generator Owners Groep (SW ) guidelines and the Electric Power Resem h lnstitute (EPRI) guidelines foi seconur, N Ptemistry, as well as NUREG 0452, Revision 4, "Sm/.dami Technical

pecificas for Westinghouse Pressurized Water Raactors "

E BACK. GROUND Technical Specification 6.8.4.c(v!i) wcs a condition established for obtaining the full pownr license for North Anna Unit 2. Technical Specification 6.8.4.c(vii) was implemented in license amendment number 32 for North Anna Unit 1. The NRC's decision to require the licensee to establish monitoring and repair of condenser inteakage is discussed in NUREG 0053, Supplement 10, Sately Evaluation Report for

-North Anna Power Station. NUREG 0053 states the following:

• we require monitonng of the steam condensate at the effluent of the condentate pump. When condenser leakage is confirmed the applicant will be required to repak or plug tbc leale in accordance with MTE3 Branch Technical Position MTEB 5-3 attached to Standard Review Plan 5A.2.1" MTEB Branch Technical Position MTEB 5-3 (MTEB 5-3) descritaes the suggested secondary water chemistry program in order to maintain steam generator integrity.

MTED S-3 is dated July 1981 and states the following:

• ll.3.f.11)(f) When a condenser leak is confimled, the leak should be repaired or plugged within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, or before the totalintegrated conductivity increase reaches 20 prnho/cm hrs. The staff

will consider other impurity >!me limit proposals for limiting the quantity of impurities entering the stea a generator"

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i SGOG guidelines and EPRI guidelines for secondary water chemistry were established in February 1985 and December 1988, respectively. These guidelines have been established as industry accepted standards arid are more aggressive than the MTEB 5-3 position with regard to establishing actions for confirmation and repair of condenser inleakage. MTEB 5-3 places requirements on condenser inteakage and the SGOG and EPRI guidelines address t5e steam generator chemistry. SGOG and EPRI guidelines have established chemistry specifications to ensure secondary water chemistry is maintainea at conditions to prevent steam generator corrosion.

SPECIFIC CH ANGES General The Techtdcal Specification changes described herein apply to North Anna Units 1 and 2.

Technical S D.ecification 6.8.4.c The proposed changes will modify Technical Specification 6.8.4.c(iii) and delete Technical Specification 6.8.4.c(vii). Technical Specification 6.8.4.c(iii) and (vii) currently state the following:

• c. Secondary Watei Chemistrv A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation. This program shall include:

(iii) Identification of pmcess sampling points,

-h (vii) Monitoring of the condensate at the discharge of the condensate pumps for vidence cf ondenser inleakage. When condenser inleakage is confirmed, the leak shah be repaired, piogged, or isolated within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> "

The revised Technical Specification 6.8.4.c(iii) will read as foilows:

"(iii) Identification of process sampling points, .vhich shallincluoe monitoring the discharge of the condensate pumps for evidence of condenser Weakage,'

The purpose if the revised Technical Specification 6.8.4.c(iii) is to retain the requirement in Technical Specification 6.8.4.c(vii) for monitoring condenser inleakage.

The proposed changes delete the ninety six (96) hour requirement in Technical

~ Specification 6.8.4.c(vii) becauw condenser inteakage is difficult to identify until it reaches a certain threshold and bolation or repair is not always feasible within ainety six (96) hours. MTEB 5-3 guidelines were the basis for Technical Specification G.8.4.c(vii) l

I u l and.were established in the late 1970's. These requirements do not reflect current l

. secondary water chemistry practices. l 1

-These changes [ deletion of Technical Specification 6.8.4.c(vii) and modification of l Technical Specification 6.8.4.c(iii)) are consistent with the SGOG and EPRI guidelines l and will continue to ensure that the condensate at the discharge of the condensate l pumps will be monitored in order to detect condenser inleakage, The SGOG and EPRI guidelines have established appropriate action levels to be  ;

entored when a chemistry paramete is not maintain

• For example, the normal value for condenser inleakage is less than ' cur cubic feu er minute (cfm) in!eakage, if condenser inleakage exceeds four cfm, action level one is entered into to promptly identify and correct the cause of the out of normal value without power reduction. The spacific action required is to return condenser inleakage to within the normal value within one week. However, condenser inteakage outside normal values will cause other secondary water chemiatry parameters to be outside their specified limits. Appropriate actions to maintain other secondary water chemistry parameters within specified limits may include such actions as reducing power or a plant shutdown.

L North Anna has_ incorporated chemistry parameter action levers into station administrative procedures. These action levels ensure a more aggressive approach than MTEB. 5 3 for condenser inleakage.

This will replace, in part, Technical Specification 6.8.4.c(vii) that discussed the action time associated with cnnfirmation of cordenser_ inleakage. In addition, editorial changes are proposed to Technical Specifications 6.8.4.c(v) and 6.8.4.c(vi).

. The proposed chr. ages are consistent with the SGOO guidelines, EPRI guidelines, and NUREG-0W.; Revision 4, Standard Technical Specifications for Westinghouse Pressurized Water Reactors.

SAFETY SIGNIFICANCE The SGOG-and EPRI guidelines .have been established to monitor and initiate

-corrective actions in the event of condenser inleakage. Monitoring oi the condensate at <

the discharge of the condensate purnps will continue to be performed in order to detect

_ condenser inleakage. This is' reflected in proposed Technical Specil< cation 6.8.4.c(iii) and documented in station administrative procedures.

~ The SGOG and EPRI guidelines are more conservative than MTEB 5-3. MTEB 5 3 ,

places requirements on condenser inteakage and the SGOG and EPRI guidelines .l add (ess the steam generator chemistry. The steam generator chemistry control' parameters can be exceeded without a noticeable ingress of contaminants from the condensate. Damage to the steam generators can be-sustained due to the concentration of contaminants in the steam generator, without exceeding the Technical Specification .IlmitLon condenser inteakage. SGOG and EPRI guideiines have l

< -established chemistry specifications iv ensure secondary water chemistry is maintained  !

at conditions to prevent steam generator corrosion. i

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