ML20205S658

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Safety Evaluation Supporting Amend 80 to License NPF-4
ML20205S658
Person / Time
Site: North Anna Dominion icon.png
Issue date: 05/27/1986
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20205S652 List:
References
NUDOCS 8606120737
Download: ML20205S658 (3)


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NUCLEAR REGULATORY COMMISSION 5

A WASHINGTON, D C. 20555 y'..v l,E SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l

RELATED TO AMENDt'ENT NO. 80 FACILITY OPERATING LICENSE NO. NPF-4 VIRGINTA ELECTRIC AND POWER COMPANY OLD DOMINION ELECTRIC COOPERATIVE NORTH ANNA POWER STATION, UNIT NO. 1 DOCKET NO. 50-338

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Introduction:==

By letter dated May 17, 1985, as superseded November 15,1985,(Serial Nos.85-306 and 85-306A), the Virginia Electric and Power Company (the licensee) proposed changes to the Technical Specifications (TS) for the North Anna Power Station, Unit No. 1 (NA-1). Specifically, the proposed chances would correct errors in the TS of seismic instrument range and testing requirements. The proposed changes would also delete the functional test requirement for the Auxiliary Building Mat, Reactor Heat Removal (RHR)

Pipe Support and Component Cooling Heat Exchanger Support.

In addition, the proposed changes would modify the scope of the semi-annual channel functional test of the Containment Mat Triaxial Recorder.

Discussion:

As presently specified, TS Table 3.3-7 lists the instrument measurenent rance to be Og to 349 for the triaxial response spectrum recorders. The correct range should be 1.0 H to 30 H and is consistent with the American National StandardsInstitute(dNSI)/AmeficanNuclearSociety(ANS).

The current surveillance requirements for seismic monitoring instrumentation require semi-annual functional tests for the four triaxial response recorders listed in TS Table 4.3-4 Three of these recorders (the Auxiliary Building Mat, RHR Pipe Support and Component Cooling Heat Exchanger Support 1 are passive devices with no remote indications. Guidance provided by NRC Pegulatory Guide 1.17, 1974, and ANSI /ANS Standard ?.2, 1978, indicate that these recorders do not require a channel functional test.

Table 1 of AMSI/ANS Standard 'd.2 on frecuency of maintenance specifically recommends that no channel functional test be performed for self contained, passive instruments.

The proposed change would revise the specifications to be consistent with current regulatory guidance and also the manufacturer's recommendations.

The fourth of these triaxial response recorders is the Containment Mat tri-axial response recorder. This recorder is an inaccessible, active device with a renote indication fannunciatori.

Present surveillance requirements soecified in the NA-1 TS reouire semi-annual functienal testing of this recorder. The containment mat triaxial response recorder is the only one 8606120737 860527' PDR ADOCK 05000338 P

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b a of these passive devices with a remote indication (annunciatori. The recorder itself is primarily a mechanical device, consisting of an event recording plate and a scriber. Durino a seismic event, the scriber will record scriber shank deflection by etching the motion on the plate. This plate would sub-sequently be removed for post-event analysis. The associated annunciator is used to alert the operator that the device has recorded scriber motion.

Within the recorder, the annunciator circuitry consists of alarm contacts which interface with the scriber should significart motion occur. The current NA-1 TS require that this instrument be opened and the scriber be moved by hand until the contacts close and a light in the remote indicator illuminates to satisfy the channel functional test requirements.

Past semi-annual functional testing of the containnent mat recorder has reouf red containment entry f at power) which requires commensurate protective clothing, self-centained breathing apparatus and limited access time because of ALARA concerns.

past semi-annual testing has resulted in damege to the equipment such as a bent scriber shank or bent annunciator contacts since personnel must manipulate the scriber with bulky protective gloves. Also, based on past semi-annual testing, corrosion problems and broken contacts have occurred. Also, it is postulated that the occurrence of corrosion within the recorder has been caused by the introduction of high humidity environments into the internals of the containment mat triaxial device during functional testing.

Evaluation:

Revising the instrument measurerent range presently specified in the NA-1 TS Table from 0g-349 to 1.0H - 30H is in accordance with the ANSI /ANS standards that apply to NA-1.

TherIfore,defindthischangeacceptable.

The proposed change, which would eliminate the channel functional test on a semi-annual basis for the Auxiliary Building Mat, RHR Pipe Support and Component Cooling Heat Exchanger Support triayfal recorders, meets the guidance provided in ANSI /ANS Standard ?.2 for passive devices.

In addition, the proposed charce would also specify a monthly visual inspection of " accessible" recorders for signs of obvious physical damage. Consistent with ANSI /ANS ?.?, which defines

" accessible" as " instrument or sensors whose locations permit ready access l

during plant operations," nonthly visual inspections would be limited to the l

Auxiliary Ruilding Fat and Component Cooling Heat Exchanger recorders located l

outside containment. The proposed change would not affect the refueling cherrel calibration requirement, which remains unchanged. Therefore. based on the above, we find this change to be acceptable.

The NRC staff agrees with the licensee that the requirement to cren the Contain-rent Mat triaxial response recorder and manipulate the scriber for the Channel Functional Test is not warranted.

In addition, the proposed change wnuld delete the seni-annual functional test for the Containrer.t Mat triaxial responec recorder.

The prcposed change is consistent with ANSI /ANS 2.? for passive devices. The proposed change would include a monthly anrunciator check of the Containment "at l

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e triayfal recorder. The nonthly annunciator check of the containment triaxial recorder is consistent with ANSI /ANS Standard 2.2 for channel checks of active devices. Active devices are defined by the Standard as " instruments recuiring a power source to sense motion or to record data." As such, only the annunciator of the contairment mat triaxial recorder would be treated as an active device.

The proposed change would not affect the refueling channel requirement, which remains unchanged. Therefore, based on the above, we find this change to be acceptable.

Implementation Schedule Implementation of the f'A-1 TS changes discussed above become effective er the date specified below.

Environmental Conrideration This amendment involves a change in the insta11atier or use of a facility component located within the restricted area es defined in 10 CFR Part 20.

The staff has determined that the amendment invcives no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously published a proposed finding that the anendment involves no significant hazards consideration and there hes been no public comment on such finding. Accordinoly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 651.22(c)(91 Pursuant to 10 CFR 951.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Conclusion We have concluded, based on the considerations discussed above, that (1) there is reasonable assurarce that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activitier will be conducted in compliance with the Commission's regulations, and the issuance of the anendment will not be inimical to the common defense and security or to l

the health and safety of the public.

Date:

May 27,1986 Principal Contributors:

H. Polk and L. Engle l

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