ML20214T127
| ML20214T127 | |
| Person / Time | |
|---|---|
| Site: | North Anna, Susquehanna |
| Issue date: | 05/13/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20214T117 | List: |
| References | |
| NUDOCS 8706100135 | |
| Download: ML20214T127 (3) | |
Text
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION
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i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT.NOS. 95 AND 80 TO FACILITY OPERATING LICENSE NOS. NPF-4 AND NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY OLD DOMINION ELECTRIC COOPERATIVE NORTH ANNA POWER STATION, UNITS NO. 1 AND NO. 2 DOCKET NOS. 50-338 AND 50-339 j
INTRODUCTION i
By letter dated April 10, 1986, the Virginia Electric and Power Company (the licensee) proposed changes to the Technical Specifications (TS) for the North Anna Power Station, Units No. I and No. 2 (NA-182). Specifically, the proposed changes would differentiate the requirements of the NA-1&2 Technical Spec ~1fication (TS) 3/4.3.3.3.7 (fire detection instrumentation) for inside and outside of i
containment. Also, the changes would modify the surveillance interval for fire detection instruments in containment to every cold shutdown exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed within the previous six months.
In addition, the proposed changes would replace the one hour fire watch requirements for containment fire
- t zones which have inoperable fire detection instrumentation with an inspection.
l once every eight hours or hourly monitoring of containment air temperature.
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These changes, as noted above, are consistent with the requirements for fire
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detection instrumentation specified in the Westinghouse Standard Technical Specifications for Pressurized Water Reactors, NUREG-0452. Revision 4, TS l
3/4.3.3.3.8 and which appropriately applies to NA-182 TS 3/4.3.3.3.7.
Technical Specification 3/4.3.3.3.8, NUREG-0452, Revision 4 states in part:
l "With the number of OPERABLE fire detection instrument (s) less than the minimum number Operable requirement.... Within I hour establish a fire watch patrol to inspect the zone (s) with the inoperable instrument (s) at least once per hour,-
unless the instrument (s) is located inside the containment, then inspect the containment at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or (monitor the containment air temperature at least once per hour...)."
The appropriate surveillance requirement to l
75 3/4.3.3.3.8 states in part: "... Fire detectors which are not accessible during plant operation shall be demonstrated Operable... during each COLD SHUTDOWN exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed in the previous 6 months."
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DISCUSSION NA-182 are designed with subatmospheric containments. The corresponding NA-1&2 l
TS requires that the containments be maintained subatmospheric during operations l
in Modes 1 through 4.
Under these specified subatmospheric conditions, the containment environment is oxygen-deficient, thereby requiring respiratory protection. As a consequence, it is prudent to limit personnel entry into containment during subatmospheric modes of operation.
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0706100135 870513 PDR ADOCK 05000330 P
The present NA-1&2 surveillance requirement specifies a functional test of fire detection instrumentation every six months. This requires a containment entry every six months to perform the test. Testing of fire detection instrumentation inside containment has resulted in extended stay times, subjecting personnel to radiation exposure as well as the oxygen-deficient environment of the subatmospheric containment. Consistent with Standard Technical Specification 3/4.3.3.3.8 on fire detection instrumentation, the licensee has identified "not accessible during plant operation" as referring to "inside containment" and would modify the surveillance interval for fire detection instruments inside containment to every cold shutdown exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed within the previous six months.
Independent of personnel safety concerns, there are a sufficient number of redundant or diverse fire detectors in the containment fire zones to justify the proposed change in surveillance interval.
Likewise, the present NA-182 TS 3/4.3.3.3.7 action statement requires an hourly fire watch patrol in containment to inspect those containment fire zones which had inoperable fire detection instrumentation. This requimment is impractical, independent of personnel safety concerns, due to the difficulty of implementing hourly entries into containment. A containment entry / exit typically takes 10 minutes due to the time for depressurization/ pressurization in the air lock.
This does not consider the time to don / remove anti-contamination clothing and respirator and travel through access control areas.
Furthermore, hourly inspection of containment spaces is not justified given the relative lack of consumable material compared to areas outside of containment. Monitoring containment air temperature on a hourly basis or a visual inspection of containment every eight hours is an appropriate compensatory action to take in the event of instrument inoperability until the minimum required number of fire detection devices have been restored operable and is consistent with TS 3/4.3.3.3.8 as noted above.
EVALUATION The proposed changes do not increase the likelihood of an undetected fire in containment. The proposed compensatory measures of hourly temperature monitoring or visual inspection of containment every eight hours provide adequate interim fire detection capability until the minimum required number of fire detection devices have been restored operable. Likewise, the proposed change to the functional testing interval for fire detection instrumentation in containment merely modifies the test frequency during sustained power operations. As mentioned above, there are a sufficient number of redundant or diverse fire detectors in the containment fire zones to ensure detection and justify the proposed change in the surveillance interval. Finally, the proposed changes still require adequate functional testing of fire detection instrumentation and compensatory inspections or hourly temperature monitoring consistent with the Westinghouse Standard Technical Specifications for Pressurized Water Reactors, NUREG-0452, Revision 4, which appropriately apply to NA-1&2. Based on the above, we find the proposed changes to be acceptable.
EWIRONMENTAL CONSIDERATION These amendments involve a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requirements. The staff has detemined that the
e 9 amendments involve 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 radiatior exposure. The Commission has previously published a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 551.22(c)(9).
Pursuant to 10 CFR 551.22(b), no environmental impact statement or environmental a'ssessment need be prepared in connection with the issuance of these amendments.
CONCLUSION We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendments will not be inimical to the connon defense and security or to the health and safety of the public.
Date: May 13, 1987 Principal Contributor:
Leon B. Engle t
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