ML20214R325

Proposed Tech Specs Consisting of Several Administrative Changes to Primary Coolant Specific Activity Limits in Order to Conform to Generic Ltr 85-19

ML20214R325
Person / Time
Site:	North Anna
Issue date:	06/01/1987
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20214R321	List: ML20214R319 ML20214R325
References
GL-85-19, NUDOCS 8706080082
Download: ML20214R325 (15)

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i ATTACHMENT 1 PROPOSED CHANGES TO NORTH ANNA UNIT 1 TECHNICAL SPECIFICATIONS 8706080082 870601 PDR ADOCK 05000338 P

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REACTOR COOLANT SYSTEM 3/4.4.8 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the primary coolant shall be limited to:

a.

s 1.0 pCi/ gram DOSE EQUIVALENT I-131, and b.

s 100/E pCi/ gram.

APPLICABILITY: MODES 1, 2, 3, 4 and 5.

ACTION: MODES 1, 2 and 3*

With the specific activity of the primary coolant > 1.0 pCi/ gram DOSE a.

EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure 3.4-1, be in at least HOT STANDBY with T,yg < 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With the specific activity of the primary coolant > 100/E pCi/ gram, be in at least HOT STANDBY with T

< 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

avg MODES 1, 2, 3, 4 and 5 a.

With the specific activity of the primary coolant > 1.0 pCi/ gram DOSE EQUIVALENT I-131 or > 100/E pCi/ gram, perform the sampling and analysis requirements of item 4a of Table 4.4-4 until the specific activity of the primary coolant is restored to within its limits.

• With T,y greater than or equal to 500*F NORTH ANNA - UNIT I 3/4 4-22 Amendment No.

e REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION 4

SURVEILLANCE REQUIREMENTS 4.4.8 The specific activity of the primary coolant shall be determined to be within the limits by performance of the sampling and analysis program of Table 4.4-4.

NORTH ANNA - UNIT 1 3/4 4-23 Amendment No.

.T

REACTOR COOLANT SYSTEM BASES The ACTION statement permitting POWER OPERATION to continue for limited time periods with the primary coolant's specific activity

>1.0 pCi/ gram DOSE EQUIVALENT I-131, but within the allowable limit shown on Figure 3.4-1, accommodates possible iodine spiking phenomenon which may occur following changes in THERMAL F0VER.

Reducing T to <500*F prevents the release of activity should a steam generator tuh rupture since the saturation pressure of the primary coolant is a

below the lift pressure of the atmospheric steam relief valves.

The surveillance requirements provide adequate assurance that excessive specific activity levels in the primary coolant will be detected in sufficient time to take corrective action.

Information obtained on iodine spiking will be used to assess the parameters associated with spiking phenomena.

A reduction in frequency of isotopic analyses following power changes may be permissible if justified by the data obtained.

3/4.4.9 PRESSURE / TEMPERATURE LIMITS All components in the Reactor Coolant System are designed to withstand the effects of cyclic loads due to system temperature and pressure changes.

These cyclic loads are introduced by normal load transients, reactor trips, and startup and shutdown operations.

The various catagories of load cycles used for design purposes are provided in Section 5.2 of the FSAR.

During startup and shutdown, the rates of temperature and pressure changes are limited so that the maximum specified heatup and cooldown rates are consistent with the design assumptions and satisfy the stress limits for cyclic operation.

During heatup, the thermal gradients in the reactor vessel wall produce thermal stresses which vary from compressive at the inner wall to tensile at the outer wall. These thermal induced compressive stresses tend to alleviate the tensile stresses induced by the internal pressure.

Therefore, a

pressure-temperature curve based on steady state conditions (i.e., no thermal stresses) represents a lower bound of all similar curves for finite heatup rates when the inner wall of the vessel is treated as the governing location.

NORTH ANNA - UNIT 1 B 3/4 4-6 Amendme.nt No.

ADMINISTRATIVE CONTROLS ANNUAL REPORTS 6.9.1.4 Annual reports covering the activities _of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year.

The initial report shall be submitted prior to March 1 of the year following initial criticality.

6.9.1.5 Reports required on an annual basis shall include:

a.

A tabulation on an annual basis of the number of station, utility, and other personnel (including contractors) receiving exposures according to work and job functions,fj associated greater than 100 mrem /yr and thef man-rem exposure e.g.,

reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling.

The dose assignments to various duty functions may be estimated based on pocket dosimeter,

TLD, or film badge measurements.

Small exposures totalling less than 20 percent of the individual total dose need not be accounted for.

In the aggregate, at least 80 percent of the total whole body dose received from external sources should be assigned to specific major work functions.

b.

The complete results of the steam generator tube inservice inspections performed during the report period (Reference Specification 4.4.5.5.b.).

c.

The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8.

The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2)

Results of the last isotopic analysis for radiciodine performed prior to exceeding the limit, results of analysis while limit was exceeded and results of one analysis after the radioiodine activity was reduced to less than limit. Each result should include date and time of sampling and the radioiodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radioiodine limit.

1/

A single submittal may be made for a multiple unit station.

The.

submittal should combine those sections that are common to all units at the station.

2/

This tabulation supplements the requirements of $20.407 of 10 CFR Part j

20.

NORTH ANNA - UNIT 1 6 Amendment No.

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ADMINISTRATIVE CONTROLS (Continued)

SPECIAL REPORTS 6.9.2 Special reports shall be submitted to the Regional Administrator, Region II, within the time period specified for each report.

These reports shall be submitted covering the activities identified below pursuant to the requirement of the applicable reference specification:

a.

Inservice Inspection Program Reviews shall be reported within 90 days of completion.

Specification 4.0.5.

b.

ECCS Actuation shall be reported within 90 days of the occurrence.

The report shall describe the circumstances of the actuation and'the total accumulated cycles to date.

Specifications 3.5.2 and 3.5.3.

c.

With Seismic Monitoring Instrumentation inoperable for more than 30 days, submit a special report within the next 10 days outlining the cause of the malfunction and the plans for restoring the instrumentation to operable status.

Specification 3.3.3.3.

d.

For all seismic events actuating a seismic monitoring instrument, submit a special report within 10 days describing the magnitude, frequency spectrum and resultant effects upon features important to safety. Specification 4.3.3.3.2.

e.

With Meteorological Instrumentation inoperable for more than 7 days, submit a special report within the next 10 days, outlining the cause of the malfunction and the plans for restoring the instrumentation to operable status. Specification 3.3.3.4.

f.

Deleted.

g.

With sealed source or fission detector leakage tests revealing the presence of 20.005 microcuries of removable contamination submit a special report on an annual basis outlining the corrective actions taken to prevent the spread of contamination.

Specification 4.7.11.1.3.

h.

With the MTC more positive than 0 Ak/k/*F submit a special report within the next 10 days describing the value of the measured NTC, the interim control rod withdrawal limits and the predicted average core burnup necessary for restoring the positive MTC to within its limit for the all rods withdrawn condition. Specification 3.1.1.4.

NORTH ANNA - UNIT 1 6-21 Amendment No.

1 ATTACHMENT 2 PROPOSED CHANGES TO NORTH ANNA UNIT 2 TECHNICAL SPECIFICATIONS Y

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REACTOR COOLANT SYSTEM 3/4.4.8 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the primary coolant shall be limited to:

a.

Less than or equal to 1.0 pCi/ gram DOSE EQUIVALENT I-131, and b.

Less than or equal to 100/E'pCi/ gram.

APPLICABILITY: MODES 1, 2, 3, 4 and 5.

ACTION: MODES 1, 2 and 3*

a.

With the specific activity of the primary coolant greater than 1.0 pCi/ gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure 3.4-1, be in at least HOT STANDBY with T less than 500*F within 6 avg hours.

b.

With the specific activity of the primary coolant greater than 100/E pCi/ gram, be in at least HOT STANDBY with T less than 500*F within

"#E 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

• With T greater than or equal to 500*F NORTH ANNA - UMIT 2 3/4 4-22

-Amendment No.

REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION ACTION:

(Continued)

MODES 1, 2, 3, 4 and 5 a.

With the specific activity of the primary coolant greater than 1.0 pCi/ gram DOSE EQUIVALENT I-131 or greater than 100/E pCi/ gram, perform the sampling and analysis requirements of item 4a of Table 4.4-4 until the specific activity of the primary coolant is restored to within its limits.

SURVEILLANCE REQUIREMENTS 4.4.8 The specific activity of the primary coolant shall be determined to be within the limits by performance of the sampling and analysis program of Table 4.4-4.

NORTH ANNA - UNIT 2 3/4 4-23 Amendment No.

REACTOR COOLANT SYSTEM BASES The ACTION statement permitting POWER OPERATION to continue for limited time periods with the primary coolant's specific activity greater than 1.0 pCi/ gram DOSE EQUIVALENT I-131, but within the allowable limit shown on Figure 3.4-1, accommodates possible iodine spiking phenomenon which may occur following changes in THERMAL POWER.

Reducing T to less than 500*F prevents the release of activity should a generYikor tube rupture since the saturation pressure of the primary steam coolant is below the lift pressure of the atmospheric steam relief valves.

The surveillance requirements provide adequate assurance that excessive specific activity levels in the primary coolant will be detected in sufficient time to take corrective action.

Information obtained on iodine spiking will be used to assess the parameters associated with spiking phenomena.

A reduction in frequency of isotopic analyses following power changes may be permissible if justified by the data obtained.

3/4.4.9 PRESSURE / TEMPERATURE LIMITS The temperature and pressure changes during heatup and cooldown are limited to be consistent with the requirements given in the ASME Boiler and Pressure Vessel Code,Section III, Appendix G.

1)

The reactor coolant temperature and pressure and system heatup and cooldown rates (with the exception of the pressurizer) shall be limited in accordance with Figures 3.4-2 and 3.4-3 for the first full-power service period.

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NORTH ANNA - UNIT 2 B 3/4 4-6 Amendment No.

ADMINISTRATIVE CONTROLS b.

The complete results of the steam generator tube inservice inspections performed during the report period (Reference Specification 4.4.5.5.b.).

c.

The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8.

The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2)

Results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while limit was exceeded and results of one analysis after the radiciodine activity was reduced to less than limit. Each result should include date and time of sampling and the radiciodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration and one other radiciodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radioiodine limit.

MONTHLY OPERATING REPORT 6.9.1.6 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the Reactor Coolant System PORVs

]

or safety valves, shall be submitted on a monthly basis to the Director, Office of Management and Program Analysis, U.

S.

Nuclear Regulatory Commission, Washington, D.

C.

20555, with a copy to the Regional Office of Inspection and Enforcement, no later than the 15th of each month following the calendar month covered by the report.

NORTH ANNA - UNIT 2 6-16 Amendment No.

ADMINISTRATIVE CONTROLS (Continued)

SPECIAL REPORTS 6.9.2 Special reports shall be submitted to the Regional Administrator, Region II, within the time period specified for each report.

These reports shall be submitted covering the activities identified below pursuant to the requirement of the applicable reference specification:

a.

Inservice Inspection Program Reviews shall be reported within 90 days of completion.

Specification 4.0.5.

b.

ECCS Actuation shall be reported within 90 days of the occurrence.

The report shall describe the circumstances of the actuation and the total accumulated cycles to date. Specifications 3.5.2 and 3.5.3.

c.

Deleted.

d.

With sealed sources or fission detector leakage tests revealing the presence of 20.005 microcuries of removable contamination submit a special report on an annual basis outlining the corrective actions taken to prevent the spread of contnmination.

Specification 4.7.11.1.3.

e.

With the MTC more positive than 0 Ak/k/*F submit a special report within the next 10 days describing the value of the measured MTC, the interim control rod withdrawal limits and the predicted average core burnup necessary for restoring the positive MTC to within its limit for the all rods withdrawn condition.

Specification 3.1.1.4.

f.

For any abnormal degradation of the structural integrity of the reactor vessel or the Reactor Coolant System pressure boundary detected during the performance of Specification 4.4.10.1, an initial report shall be submitted within 10 days after detection and a detailed report submitted within 90 days after the completion of Specification 4.4.10.1.

g.

For any abnormal degradation of the containment structure detected during the performance of Specification 4.6.1.6.2, an initial report shall be submitted within 10 days after completion of Specification 4.6.1.6.2.

A final report, which includes (1) a description of the condition of the liner plate and concrete, (2) inspection procedure, (3) the tolerance on cracking and (4) the corrective actions taken, shall be submitted within 90 days after the completion of Specification 4.6.1.6.2.

h.

Inoperable Fire Detection Instrumentation, Specification 3.3.3.7.

i.

Inoperable Fire Suppression

Systems, Specifications 3.7.14.1, 3.7.14.2, 3.7.14.3, 3.7.14.4 and 3.7.14.5.

NORTH ANNA - UNIT 2 6-21 Amendment No.

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SAFETY EVALUATION 1

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SAFETY EVALUATION NORTH ANNA UNITS 1 AND 2 TECHNICAL SPECIFICATIONS ADMINISTRATIVE CHANGES ASSOCIATED WITH PRIMARY COOLANT SPECIFIC ACTIVITY LIMITS The following administrative changes to North Anna Unit 1 and Unit 2 Technical Specifications are being proposed for the reasons stated:

1.

Revise Specification 3.4.8 regarding reactor coolant specific activity limits to delete the requirement to shut down the plant if coolant iodine activity limits are exceeded for more than approximately 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any 12 month period (action "a" for modes 1, 2 and 3); and the requirement for a special report each time coolant iodine activity limits are exceeded (action "a" for modes 1, 2, 3, 4 and 5). These changes are in response to NRC Generic Letter 85-19, " Reporting Requirements on Primary Coolant Iodine Spikes."

The special report is to be replaced by a requirement to report on an annual basis the results of any specific activity analysis in which the primary coolant activity exceeds the limits of Specification 3.4.8 (see item 2 below). As discussed in the Generic Letter, the quality of nuclear fuel has been greatly improved over the past decade with the result that coolant iodine activity is normally well below the Tech. Specs, limit.

In

addition, 10 CFR 50.72 (b)(1)(ii) requires the licensee to immediately notify the NRC if fuel cladding failures exceed expected values or are caused by unexpected factors.

Thus the 800 hour0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> limit is no longer considered necessary on the basis that proper fuel management and existing reporting requirements should preclude over approaching the limit.

2.

Add to Section 6.9.1.5 a requirement for reporting on an annual basis the results of any specific activity analysis in which the primary coolant exceeds the limits of Specification 3.4.8, and delete from Section 6.9.2 the requirement for a special report on the same subject.

This change is in response to NRC Generic Letter 85-19 and would replace the requirement for a 30-day special report with an annual reporting requirement.

The report content has also been changed to include the information requested by the Generic Letter.

BASIS FOR NO SIGNIFICANT HAZARDS DETERMINATION The proposed changes do not involve a significant hazards consideration because operation of North Anna Units 1 & 2 in accordance with these changes would not:

(1) involve a significant increase in the probability or consequence of an accident previously evaluated. The changes involve administrative changes specified in Generic Letter 85-19.

The deletion of the requirement to shutdown if the coolant activity limit is exceeded for more than 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any 12 month period is not considered necessary because of the increased quality of nucleur fuel production and management, and the requirement of 10 CFR 50.72 (b)(1)(ii) for immediate notification if fuel clad failures exceed expected values should preclude approaching the limit.

(2) create the possibility of a new or different kind of accident-from any accident previously identified.

The changes involve administrative changes specified in Generic Letter 85-19.

The deletion of the requirement to. shutdown if the coolant activity limit is exceeded for more

.800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any 12 month period is not considered necessary because than of the increased quality of nuclear fuel production and management, and l-the requirement of 10 CFR 50.72 (b)(1)(ii) for immediate notification if fuel clad failures exceed expected values should preclude approaching the limit.

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(3) involve a significant reduction in a margin of safety. The. changes involve administrative changes specified :ht Generic Letter 85-19.

.The deletion of the requirement to shutdown if the coolant activity limit is exceeded for more than 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any 12 month period is not considered necessary because of the increased quality of nuclear fuel production and management, and the requirement of 10 CFR 50.72 (b)(1)(11) for immediate notification if fuel clad failures exceed expected values should preclude approaching the limit.

Therefore, pursuant to 10 CFR 50.92, based on the above consideration, it has 3

been determined that this change does not involve a significant safety hazards consideration.

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