ML20127D389

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Proposed TS 6.8.4.c Re Program for Monitoring Secondary Water Chemistry to Inhibit SG Tube Degradation
ML20127D389
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 09/04/1992
From:
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20127D388 List:
References
NUDOCS 9209150003
Download: ML20127D389 (8)


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ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGE UNIT 1 l

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.9209.150003 920904

.: P D R - ADOCK 05000338

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'ADMINISTRATIV5 CONTROL;S b.

In Plant Radiation Monitorifw A piogram which will ensure the capability to accurately determine the airbomo iodine concentration in v)tal areas under accident corxiitions This program shall it,clude the following:

(i)

Training of personnel, (ii)

Prccedures for monitoring, and (iii)

Provisions for maintenance of sampling and analysis equipment.

c. Sr.,gIydary Water Chemistry A program for monitoring of secondary water chemistry to inhcit steam generator tube dog,adation. ' This pn> gram shall include:

(1)

Identification of a sampling schedule for the critical variablos and controlpoints for these variables,

- (ii)

Identificalico of the procedures usod to trmsure the values of the critical

yviablos,
(iii)

Identification of process sampling points, which shallincludo monitoring the 1

oischarg, of th9 condensato pwnps for evidence of condenser inicMage, l

(iv)

Proceduros for the recordlag and management of data, (v)

Procedures defining corrective actions for all control point chemistry conditions, and (vi)

A procedure identilying (a) the authority repunsible for the interpretation of the 1

data, and (b) the sequence and tirr!ng of administrativo events required to initiate

'l costactivo action, L

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Post-ACCMQULSatDQliD.

A program whicit will ensure the capability Ic obtain and ana;/20 reac*or coolant, radioactivo iodines and particulates in plant gasecus effluents, and contabmont '

. atmosphere samples under accident conditions, The program sha;linclude the following:

(1)

Training vi personnel, (ii)

Procede:es for sampling and analysis, (iii)

Provisions for ma!ntenance of sampling and analysis equipment.

. NORTH ANNA - UNIT 1 '

- G 13a Amendtnert No. GE e e

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ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION CHANGE UNIT 2 l

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ADMIN STRATIVE CONTROLS -

b? In-Plant Radiation Monitorino A program which will ensure the capabihty to accurately determhe the airborne iodine concentration in vital areas under accident cond: lions. This program shallinclude the following:

(i)

Training of personnel, (ii)

. Procedures for monitoring, and (iii)

Provisions for maintenance of sampling and analysis equipment.

c.

Secondary Water Chemistry A program for monitoring of secondary water chemistry to inhibit steam generator tubo degradation. This program shallinclude:

l (i)

Identificaticci ot a sampling schedule for the critical variables and control points for these variables,

. (ii) -

ldentification of the procedures used to measure the values of the critical variables, (iii)

- Identification of process samoling points, wh'ch t, tall include monitoring the x,chargo of the condensate pumps for evicoce of condenser inteakage, (iv).

Procedures for the recording and mar:agement of data, (v)

Procedures defining corrective actions for all control point chemitry coMtions, and (vi) '

. A procedure identifying (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate icorrective action.

1d.. Post-Asident Samntino A program whicn will ensuro the capability to obtain and analyze reat: tor coolant,

- radioactive iodines and particulates in plant gasecus etfluents, and vontainment atriosphere sarnpies under accident conditions; The program shallinclude the following:

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(i)

- Training of personnel,

- (ii) = Procedures for sarnpling and analysis, fe

_ (iH)

Provisions for maintenance of sampling and analysis equipment.

NonIH ANNA - UNIT 2 614a Amendment No. 50-(

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1 ATTACHMENT 4 L

10 CFR 50.92 EVALUATION l

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ElGNIFICANT HAZARDS CONSIDERATION The proposed changes delete Technical Specification 6.8.4.c(vii). In addition, Technical Specification 6.8.4.c(iii) is modified to reflect the deletica of Technical Specification 6.8.4.c(vii). - Editorial changes are proposed to Technical Specifications 6.8.4.c(v) and 6.8.4.c(vi).

Technical Specification 6.8.4.c specifies a program for monitoring secondary water chemistry to inhibit steam generator tube degradation.

Specifically, Technical 1 Specification 6.8.4.c(vii) requires monitoring the condensate at the discharge of the condensate pumps:for evidence of condenser inleakage.

In addition, Technical Specification 6.6.4.c(vii)' requires a leak to be repaired, plugged, or isolated within ninety-six (96) hours after leakage confirmation.

The modification of Technical Specification 6.8.4.c(iii) will continue to require monitoring the condensate at the discharge of the condensate pumps for evidence of condenser inleakage. Repair of condenser inleakage will be conducted in accordance with station administrative procedures.

l Technical Specification 6.8.4.c(vii) was a condition established for-obtaining the full L

. power license for North - Anna Unit 2.

Technical Specification 6.8.4.c(vii) was implemented in license amendment number 32 for North Ar.na Unit 1. The NRC's dec% ion to establish monitoring and repair of condenser inleakage is discussed in NUREG 0053, Supplement 10, Safety Evaluation Report. NUREG 0053 states the following:

".we require monitoring of the steam condensate at the effluent of the condensato pump. When

. condenser leakage is confirmed the applicant will be required to repair or plug the ieak in accordance wiih MTEB Branch TechUcal Position MTEB 5-3 attached to Standard Review Plan 5.4.2.1."

.MTEB Branch Technical Potition MTEB 5-3 describes the suggested secondary water

. chemistry program in order to maintain steam generator integrity. MTEB 5-3 is dated July 1981.

-SGOG guidelincs for secondary water chemistry, and EPRI secondary water chemistry

_ guide _ines were established in February 1985 and December 1988, respectively. These l

guidelines have been established as. industry accepted standards and are more L

aggressive than the-MTEB 5-3-position with regard to establishing actions for

. confirmation and repair of condenserinteakage.

l The proposed changes will modify Technical Specification 6 8.4.c(iii) and delete TechMcal Specification 6.8.4.c(vii). Technical Specification 6.8.4.c(iii) and (vii) currently state the following:

c Sf;Condarv 'Wa'er Chemistry A program for monitoring or secondary water chemistri; to inhioit steam generator tube degradation. This program shallinclude:

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e (iii) Identification of process sampling pointJ.

(vil) Monitoring of the conderisate at the discharge of the condensate pumps for evidence of condenser inleakage. When ccndenser inleakage is confirrred, the Icak shall be repaired.

plugged, or isolated within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />

  • (li') Identification of process sampling points, which shall include monitoring the discharge of the corKlensate pumps for ovirtence of condenser inleakage,"

The purpose of the revised Technical Specification 6.8.4.c(iii) is to incorporate the requirerr.ents that ware in Technical Specification 6.8.4.c(vii) for monitoring of condenser inleakage. These changes [ deletion of Technical Specification 6.8.4.c(sii),

and modification of Technical Specification 6.8.4.c(iii)) are consistent with the SGOG 3

and EPRI guidatines and will continue to ensure that the condensate at the discharge of the condensate pumps will be monitored in order to detect condenser inleakage.

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The SGOG and EPRI guidelines ha'/o established approuriate action levels to be entered when a chemistry parameter is not maintated. For example, the norma value

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for condenser inleakage is less than four cubic feet per minute (cfm) inleakage. If concenser inleahage exceeds four cfm, action level one is entered into to promptly identi,'y and correct the cause of the out of normal value without powar redation. The spocific action required is 'o retum condenser inleakage to within the normal value within one week. However, condenser inteakage outside normal values will cause other secondary water chemistry parameters to be outside their specified limits. Appropriate actions to maintair uher secondary water chemistry parameters within specified limits may include sucn actions as reducing power or a plant shutdown.

North ~ Anna has incorporated chemistry parameter action levels into station administrative procedures. T hese action levels ensure a more aggressive approach than MTEB 5 3 for condenser inleakage.

This will rcplace, in part, Technical Specification 6.8.4.c(vii), that discussed the action time associated with cunfirmation of condenser inleakage.

In addition, editorial changes are proposed to Technical Specifications S.8.4.c(v) and 6.8.4.c(vi).

The proposed changes are consistent with the SGOG guidelines, EPRI guidelines, and NUREG - 0452 Revision 4, Standcrd Technical Specifications for Wcstinghouse Pressurized Water Reactors.

It has been do'ormined that the proposed chang 9s do not involve a significant hazards consideratW r defined in 10 CFR SO 92. This determination is based on the following

. points:

t The proposed changes do not involve a significant increase in the probability or consequences of an acci: lent previously evaluated. The proposed chancas are consistent with the SGOG guidciines, EPRI guidelines, and appiicable sections of NUREG 0452 and will continue io ensure that the condensate at the discharge

of the condensate pumps will be monitcred in order to detect condenser inteakage.

In addition, statica administrative proceduros will ensure appropriate actions are taken in the event of condenser inleakage.

Likewise, the consequences of any accident previously evaluated will not increase as a result of the proposed changs. Thu SGOG gc'deliaes, EPRI guidelines and applicable sections of NUREG 0452 hate been incorporated into station administrative prccedures and ensure an aggressive npproach for condonser inlenkage by evaluating all chemistry parameters that may be affected. in addition, any applicable action levels for any chemistry parameter that may be associated with an increased condenser inteakage would also be entered.

2.

The proposed changes do not create the possibility of a new or different kind of accider.t from any accident previously evaluated. The proposed changes are consistent with SGOG guidelines, EPRI guidenes and applicable sections of NUREG 0452 that have establishad chemistry specifications to ensure secondary water chemistry is maintained al conditions to inhibit steam generator corrosion.

The proposed changes are more conservative than the current requirements.

&nco a new or different kind of failure is not created, the possibility of a new or dMferent type of accident doas not ev.ir2 i

3.

The proposed changes do not bvolve a significant reduction in a margin of safety. The results of the UPSAR eccident analyses continue to bound operation under the proposed changes. Actual plant operation will not be afiectcd since the SGOG guidelines, EPRI guidelirac and applicable sections of NUREG 0452 have been incorporated into station administrative procedures. The proposed changes do not involve a change to safety limits or limiting safety system settings.

Setpoints and operating parameters are not affected. Therefore, the margin of safety is not significantly reduced.

Based on the above significant hazards concideration evaluation, Virginia Electric and Power Company concludes that the ac^ivities associated with the proposed Technical Specification changes satisfy the no signifinant hazards consideration standards of 10 CFR 50.92(c) and, accordingly, a no significant hazards ennsideration finding is justified.

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