ML20206G881

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Proposed Tech Specs,Increasing Allowable Leakage from ECCS Components,Establishing Consistent Licensing Basis for Accidents Requiring Dose Analysis & Clarifying Requirements of CREVS
ML20206G881
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 05/03/1999
From:
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20206G866 List:
References
NUDOCS 9905100169
Download: ML20206G881 (18)


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PLAlfT SYSTDt3 E4.7.7 CONTROL ROOM EMERGENCY MA81TABILITY SYSTEMS LI'MITING CONDITION FOR OPERATION 3.7.7.1 The following control roca emergency habitability syst es shall be OPERA 8LE:

a. The emergency ventilation systs
b. The bottled air pressurization systed
c. Two air conditioning systas.

APPLICA8ILITY: MODES 1. 2, 3 and 4.

ACTION: b

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a. With either the emergency ventilation system or the bottled air presurization syste inoperable, restore the inoperable /

systs to 0PERA8LE status within 7 days or be in at least HOT \

STAND 8Y 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 />,

b. With' both the mergency ventilation system and the bottled air pressurization system inoperable, restore at least one of these systes to OPERA 8LE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STAND 8Y 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 SHUTD0WN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />,
c. With one air conditioning system inoperable, restore the / %

inoperable syste to OPERA 8LE status within 7 days or be in at (

least NOT STAN08Y wtihin 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 />. /

d. With both air conditioning systems inoperable, restore at (

least one systs to OPERA 8LE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in \

at least HOT STAND 8Y 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 />.

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NORTH ANNA - UNIT 1 3/4 7-21 Amendment No. tir-l ,

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p PLANT SYSTDts l l

BASES 3/4.7.5 ULTIMATE HEAT' SINK The limitations on the ultimate. heat sink level and temperature ensure that sufficient cooling' capacity is a'vailable to either 1) pro-vide nomal cooldown of the facility, or 2) to mitigate the effects of accident conditions within acceptable limits.

The limitations on minimum water level and maximme temperature are l based on providing a 30 day coolirig water supply to safety related equipment without exceeding their design basis temperature and is con- l tistent with the recommendations of Regulatory Guide 1.27. " Ultimate Heat Sink for Muslaar Plants", March 1974. l 3/4.7.6 FLOOD PROTECTION -

The limitation on flood protection ensures, that facility protective actions will be taken (and operation will be terminated) in the event of .

flood conditions. The limit of elevation 256 feet Mean Sea Level USGS datum is based on the maximum elevation at which facility flood control measures provide protection to safety related equipment. -

3/4.7.7 CONTROLROOMEMERGENCYHABITABILITNSYSTEMS I 4 The OPERASILITY.of the control room ventilation system ensures that

1) the ambient air temperature does not' exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled

,, by this system and 2) the control room will remain habitable.for opera-tions personnel during and following all credible accident conditions.

The OPERA 81LITY of th< s system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 ran or less whole body, or its equiva-lent. This limitation is consistent with the requirements of General Desigh Criterie 19 of Appendix "A",10 CFR 50.

3/4.7.8 SAFEGUARDS AREA VENTILATION' SYSTEM The OPEPA8ILITY of the safeguards area ventilat. ion system ensures that radioactive materials leakinp from the ECCS equipment within the pump room following a LOCA are f1 tered prior to reachin the environ-ment. The operation of this system and the resultant of ect on offsite dosage calculations was assumed in the accident analyses.

NORTH ANNA - UNIT 1 8 3/4 7-5

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. Insert (1) to LCO 3.7.7.1 Applicability:

b) During movement of irradiated fuel assemblies or during CORE A.LTERATIONS.

Insert (2) to LCO 3.7.7.1 Action:

e. With either the emergency ventilation system or the bottled air pressurization system inoperable, suspend movement ofirradiated fuel assemblies or CORE ALTERATIONS.

Insert (3) to BASES 3/4.7.7 An operable control room emergency ventilation system consists of at least two operable emergency filtration train. out of the four emergency filtration trains serving the combined Unit I and Unit 2 control room. An operable emergency filtration train shall include; an operable charcoal and HEPA filter, an operable charcoal heater, an operable flow path, and having Normal and Emergency Electrical Power available. Note that (LCO) 3.0.5 may only be used if the Normal and Emergency Electrical Power Sources are required by LCO 3.8.1.1 and 3.8.1.2.

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. .. e 21 00 PLANT SYSTEMS

_3/4.7.7 CONTROL ROOM EMERGENCY HA8ITA8ILITY SYSTEMS i LIMITING CON 0! TION FOR OPERATION 3.7.7.1' The following control room emergency habitability systems shall be OPERABLE: .

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a. The emergency ventilation system b.

The bottled air pressurization system", and

c. {

Two air conditioning systems.

APPLICA8ILITY: MODES 1, 2. 3 and 4.

ACTION: ( "[

a.

With either the emergency ventilation systes or the bottled air pfessurization system inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STAN08Y within s thehours.

30 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 b.

With both the emergency ventilation system and the bottled air pressurization system inoperable, restore at least one of these systems to OPERA 8LE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STAN08Y within within the following 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 SHUTDOW 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c.

With one air conditioning system inoperable, restore the inoperable system to OPERA 8LE status within 7 days or be in at least NOT STAN08Y within the30 following 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 hours.

l d.

With both air conditioning systems inoperable, restore at least  ;

one system to OPERA 8LE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least '

HOT STANDSY wit!hin within the following 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 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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"5 hared with Unit-1 NORTH ANNA - UNIT 2 3/4 7-18

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i PLANT SYSTEMS l 8ASES 3/4.7.5 ULTIMATE HEAT SINK.

l The limitations on the ultimate heat sink level and taperature ensure  ;

that sufficient cooling capacity is available to either 1) provide normal i cooldown within of the facility, acceptable limits. or 2) mitigate the effects of accident conditions l 1

The limitations on minimum water level and maximum temperature are based on providing a 30 day cooling water supply to safety related equipment without j exceeding their design basis temperature and is consistent with the recommenda-  !

tions of March Regulatory Guide 1.27. " Ultimate Heat Sink for Nuclear Plants",

1974.

3/4.7.6 FLO60 PROTECTION I

The limitation on flood protection ensures that facility protective actions conditions.will be taken (and operation will be terminated) in the event of flood .

The limit of elevation 256 feet Mean Sea Level USGS datum is i based on the maximum elevation at which facility flood control measures provide protection to safety related equipment.  ;

l 3/4.7.7 CONTROL ROOM EMERGENCY HA81TA8ILITY SYSTEMS l

The OPERA 81LITY of the control room ventilation system ensures that 1) the ambient air temperature does not exceed the allowable temperature for contin-uous duty rating for the equipment and instrumentation cooled by this systen and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPERA 8ILITY of this /

system in conjunction with control room design provisions is based on limiting d

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the radiation exposure to personnel occupying the control room to 5 rem or p  ;

less whole body, or its equivalent. Cumulative operation of the system with g r

the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period is sufficient to reduce the d buildup of moisture on the adsorbers and HEPA filters. This limitation is 7 j

consistent with the requirements of General Design Criteria 19 to Appendix

" A" . 10 CFR 50. .

1 3/4.7.8 SAFEGUARDS AREA VENTILATION SYSTEM The OPERABILITY of the safeguards area ventilation system ensures that radioactive materials leaking from the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. Cumulative

-operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period r is sufficient to reduce the buildup of moisture on the adsorbers and HEPA '

2 filters.

The operation of this systen and the resultant effect on offsite )

dosage ~ calculations was assumed in the accident analyses. <

. /

NORTH ANNA - UNIT 2 8 3/4 7-5

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Insert (1) to LCO 3.7.7.1 Applicability:-

c) During movement ofirradiated fuel assemblies or during CORE ALTERATIONS.

Insert (2) to LCO 3.7.7.1 Action:

e. With either the emergency ventilation system or the bottled air pressurization system inoperable, suspend movement ofirradiated fuel assemblies or CORE ALTERATIONS.

Insert (3) to B5SES 3/4.7.7 An operable control room emergency ventilation system consists of at least two operable emergency filtration trains out of the four emergency filtration trains serving the combined Unit I and Unit 2

. control room. An operable emergency filtration train shall include; an operable charcoal and HEPA filter, an operable charcoal heater, an operable flow path, and having Normal and Emergency Electrical Power available. Note that (LCO) 3.0.5 may only be used if the Normal and Emergency Electrical Power Sources are required by LCO 3.8.1.1 and 3.8.1.2.

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t Attachment 3 Proposed Technical Specifications Changes I

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l North Anna Power Station Units 1 and 2 Virginia Electric and Power Company

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Unit 1 l l

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PL' ANT SYSTEMS e

3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.7.1 The following control room emergency habitability systems shall be OPERABLE:  ;

a. The emergency ventilation system ,
b. The bottled air pressurization system , and
c. Two air conditioning systems.

' APPLICABILITY:

a. MODES 1,2,3 and 4.
b. During' movement ofirradiated fuel assemblies or during CORE ALTERATIONS.

ACTION:

a. With either the emergency ventilation system or the bottled air pressurization system inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at

-least HOT STANDBY 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 />.

b. With both the emergency ventilation system and the bottled air pressurization system inoperable, restore at least one of these systems to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY 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 />.
c. With one air conditioning system inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY 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 />.
d. With both air conditioning systems inoperable, restore at least one system to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY 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 />.
e. With either the emergency ventilation system or the bottled air pressurization system inoperable, suspend movement ofirradiated fuel assemblies or CORE ALTERATIONS.
  • Shared with Unit 2.

l p NORTH ANNA - UNIT 1 3/4 7-21. Amendment No. %,

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I PLANT SYSTEMS .

BASES 3/4.7.5 ULTIMATE HEAT SINK The limitations on the ultimate heat sink level and temperature ensure that sufficient cooling capacity is available to either 1) provide normal cooldown of the facility, or 2) to mitigate the effects of accident conditions within acceptable limits.

The limitations on minimum water level and maximum temperature are based on providing a 30 day cooling water supply to safety related equipment without exceeding their design basis temperature and is consistent with the recommendations of Regulatory Guide 1.27," Ultimate i Heat Sink for Nuclear Plants", March 1974.

3/4.7.6- FLOOD PROTECTION The limitation on flood protection ensures that facility protective actions will be taken (and operation will be terminated) in the event of flood conditions. The limit of elevation 256 feet Mean Sea Level USGS datum is based on the maximum elevation at which facility flood control measures provide protection to safety related equipment.

3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS An operable control room emergency ventilation system consists of at least two operable emergency filtration trains out of the four emergency filtration trains serving the combined Unit 1 and Unit 2 control room. An operable emergency filtration train shall include: an operable charcoal and HEPA filter, an operable charcoal heater, and operable flow path, and having Normal and Emergency Electrical Power available. Note that (LCO) 3.0.5 may only be used if the Normal and Emergency Electrical Power Sources are required by LCO 3.8.1.1 and 3.8.1.2.

The OPERABILITY of the control room ventilation system ensures that 1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPERABILITY of this system in conjunction with control room design provisions is based on ,

limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design criteria 19 to Appendix "A",10 CFR 50.

3/4.7.8 SAFEGUARDS AREA VENTILATION SYSTEM The OPERABILITY of the safeguards area ventilation system ensures that radioactive materials leaking from the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. The operation of this system and the resultant effect on offsite dosage calculations was assumed in the accident analyses.

NORTH ANNA-UNIT I B 3/4 7-5 Amendment No.

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Unit 2

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PLANT SYSTEMS t

L 3/4.7.7 CONTROL ROOM EMEROENCY H ABITABILITY SYSTEMS

. LIMITING CONDITION FOR OPERATION 3.7.7.1 The following control room emergency habitability systems shall be OPERABLE: {

a. The emergency ventilation system , l l
b. The bottled air pressurization system , and
c. Two air conditioning systems.

APPLICABILITY:

a. MODES 1,2,3 and 4.
b. During movement of irradiated fuel assemblies or during CORE ALTERATIONS.

ACTION:

a. With either the emergency ventilation system or the bottled air pressurization system inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY 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 />.
b. With both the emergency ventilation system and the bottled air pressurization system inoperable, restore at least one of these systems to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY 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 />.
c. With one air conditioning system inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY 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 />.
d. With both air conditioning systems inoperable, restore at least one system to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY 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 />.
e. With either the emergency ventilation system or the bottled air pressurization system inoperable, suspend movement of irradiated fuel assemblies or CORE ALTERATIONS.

i i

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  • Shared with Unit i 3/4 7-18 Amendment No.

. NORTH ANNA - UNIT 2

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PLANT SYSTEMS

- BASES 3/4.7.5 ULTIMATE HEAT SINK

  • The limitations on the ultimate heat sink level and temperature ensure that sufficient cooling capacity is available to either 1) provide normal cooldown of the facility, or 2) mitigate the effects of accident conditions within acceptable limits.

The limitatiers on minimum water level and maximum temperature are based on providing a 30 day cooling water supply to safety related equipment without exceeding their design basis temperature and is consistent with the recommendations of Regulatory Guide 1.27," Ultimate Heat Sink for Nuclear Plants", March 1974.

3/4.7.6 FLOOD PROTECTION The limitation on flood protection ensures that facility protective actions will be taken (and

.. operation will be terminated) in the event of flood conditions. The limit of elevation 256 feet Mean Sea Level USGS datum is based on the maximum elevation at which facility flood control measures provide protection to safety related equipment.

3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS An operable control room emergency ventilation system consists of at least two operable emergency filtration trains out of the four emergency filtration trains serving the combined Unit I and Unit 2 control room. An operable emergency filtration train shall mclude: an operable charcoal and HEPA filter, an operable charcoal heater, and operable flow path, and having Normal and Emergency Electrical Power available. Note that (LCO) 3.0.5 may only be used if the Normal and Emergency Electrical Power Sources are required by LCO 3.8.1.1 and 3.8.1.2.

The OPERABILITY of the control room ventilation system ensures that 1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPERABILITY of this system in conjunction with control room design provisions is based on

- limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its equivalent. Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

This limitation is consistent with the requirements of General Design criteria 19 to Appendix "A",

' 10 CFR 50.

3/4.7.8 ' SAFEGUARDS AREA VENTILATION SYSTEM

- The OPERABILITY of the safeguards area ventilation system ensures that radioactive materials leaking from the ECCS equipment within the pump room following a LOCA are filtered prior to reaching the environment. Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. The operation of this system and the resultant effect on offsite dosage calculations was assumed in the accident analyses.

NORTH ANNA - UNIT 2 B 3/4 7-5 Amendment No.

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Attachment 4 -

Significant Hazards Consideration Determination North Anna Power Station Units 1 and 2 Virginia Electric and Power Company

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Virginia Power has reanalyzed the offsite and control room doses for the following postulated j accidents at North Anna: 1 L

l' 1) Loss of Coolant ' Accident (LOCA)

2) Main Steam Line Break (MSLB) l 3) Steam Generator Tube Rupture (SGTR)

, 4) Locked Rotor Accident (LRA)

L l The LOCA was reanalyzed to increase the amount of allowable leakage from ECCS components from 900 cc/hr to 4800 cc/hr and was performed using the LOCADOSE code. The remaining accidents were reanalyzed with the LOCADOSE code using methodology consistent with the Standard Review Plan (Reference 1) to establish a consistent basis for the North Anna dose analyses.

The intent of this submittal is to have all of the analyses performed with the LOCADOSE code. The

current analysis of record for the Fuel Handling Accident is based on the LOCADOSE code and is currently up to date and therefore, was not reanalyzed.

Compared with our previous submittal for North Anna control room habitability (letter serial number 89-022, March 1,1989), these new analyses do not take credit for recirculation of the control room I

air during the accidents. To make the North Anna Technical Specifications consistent with new analyses, Virginia Electric'and Power Company is proposing revisions to the North Anna Units 1 and 2 control room emergency habitability systems Technical Specifications. These changes would l l include operability, applicability, action statements and bases consistent with the revised dose calculations.

The dose consequences of the LOCA, MSLB, SGTR, and LRA accidents were determined to meet the 10 CFR 100 limits and the limits specified in GDC-19. While the radiation doses meet the required design limits, the projected control room thyroid dose for the LOCA, calculated under the conditions specified by the revised Technical Specifications, has increased above those calculated in the current analysis of record. In addition, some of the EAB and/or LPZ doses for certain of,the accidents exceed those values reported in the UFSAR. However, it has been determined that the i proposed changes to the North Anna Technical Specifications for the control room emergency ventilation system and the revised dose analyses do not involve a significant hazards consideration as described in 10 CFR 50.92. The results of this determination can be stated as follows:

1. There is no significant change in the probability or consequences of an accident previously evaluated. There are no system changes which would increase the probability of occurrence of an accident. The dose consequences of the accidents have been reviewed, and in some cases the l

. doses at the EAB doses and the doses to the control room personnel were found to increase.

However, this increase is not significant because the revised doses remain below the limits of 10 CFR 100 and below the limits of GDC-19 of Appendix A of 10 CFR 50.

2. No new accident types or equipment malfunction scenarios have been introduced. Therefore, the possibility of an accident of a different type than any evaluated previously in the UFS AR is not created.
3. There is no significant reduction in the margin of safety, as the revised dose calculations for all

. accidents continue to meet the appropriate GDC-19 limits.

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