ML062920444
| ML062920444 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/26/2006 |
| From: | Kobetz T NRC/NRR/ADRO/DIRS/ITSB |
| To: | Marinos E NRC/NRR/ADRO/DORL/LPLC |
| Hearn, P, NRR/DIRS/ITSB, 301-415-1189 | |
| References | |
| TAC MD2107, TAC MD2108 | |
| Download: ML062920444 (4) | |
Text
October 26, 2006MEMORANDUM TO:Evangelos C. Marinos, ChiefPlant Licensing Branch C Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationFROM:Timothy K. Kobez, Chief /RA/Technical Specifications BranchDivision of Inspection and Regional Support
SUBJECT:
SAFETY EVALUATION INPUT FOR NORTH ANNA LICENSEAMENDMENT TO ADOPT TSTF-374 AS PART OF THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)The Technical Specifications Branch (ITSB) has completed its plant-specific safety evaluation(SE) in response to submittals of Virginia Electric Power Company on May 30, 2006 and June 30, 2006, which requested adoption of TSTF-374. ITSB found the licensee's submittal acceptable. This completes ITSB's work on TAC number(s) MD2107 and MD2108. Based on previousapprovals of amendments adopting TSTF-374, ITSB does not recommend routing the final amendment package through the Office of General Counsel.Sincerely,Timothy J. Kobez, ChiefTechnical Specifications Branch Division of Inspection and Regional Support Office of Nuclear Reactor RegulationCONTACT:P. C. Hearn, DIRS/ITSB(301) 415-1189 October 26, 2006MEMORANDUM TO:Evangelos C. Marinos, ChiefPlant Licensing Branch C Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationFROM:Timothy K. Kobez, Chief /RA/Technical Specifications BranchDivision of Inspection and Regional Support
SUBJECT:
SAFETY EVALUATION INPUT FOR NORTH ANNA LICENSEAMENDMENT TO ADOPT TSTF-374 AS PART OF THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)The Technical Specifications Branch (ITSB) has completed its plant-specific safety evaluation(SE) in response to submittals of Virginia Electric Power Company on May 30, 2006 and June 30, 2006, which requested adoption of TSTF-374. ITSB found the licensee's submittal acceptable. This completes ITSB's work on TAC number(s) MD2107 and MD2108. Based on previousapprovals of amendments adopting TSTF-374, ITSB does not recommend routing the final amendment package through the Office of General Counsel.SincerelyTimothy J. Kobez, ChiefTechnical Specifications Branch Division of Inspection and Regional Support Office of Nuclear Reactor RegulationCONTACT:P. C. Hearn, DIRS/ITSB(301) 415-1189Distribution
- ITSB RFTKobezPCHearnAccession Number: ML062920444 OFFICEDIRS/ITSBDIRS/ITSB/BCNAMEPHearnTKobez DATE10/26/200610/26/2006Official Record Copy SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONTECHNICAL SPECIFICATION TASK FORCE CHANGE TRAVELER TSTF-374, Rev.0REVISION TO STS 5.513 AND ASSOCIATED STS BASES FOR DIESEL FUEL OIL
1.0 INTRODUCTION
By letters dated May 30, 2006 and June 30, 2006, Virginia Electric and Power Company(Dominion) submitted Technical Specification Task Force Change Traveler, TSTF-374, R.0, "Revision to STS 5.5.13, "Diesel Fuel Oil Testing Program" and associated TS Bases for Diesel Fuel Oil". Specifically, the proposed revisions to STS 5.5.13 relocate the specific AmericanSociety for Testing and Materials (ASTM) Standard from the Administrative Controls Section of TS to a license-controlled document. STS 5.5.13 contains the testing requirements for both new fuel oil and stored fuel oil. TheDiesel Fuel Oil Testing Program includes sampling and testing requirements and acceptance criteria.
2.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plantoperating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems and components that are required to protect the health and safety of the public. The Commission's regulatory requirements related to the content of the TSs are contained in 10 CFR Section 50.36. That regulation requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings (50.36(c)(1)); (2) Limiting Conditions for Operation (50.36(c)(2)); (3)
Surveillance Requirements (50.36(c)(3)); (4) design features (50.34(c)(4)); and (5) administrative controls (50.36(c)(5)).In general, there are two classes of changes to TSs: (1) changes needed to reflectmodifications to the design basis (TSs are derived from the design basis), and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of TSs over time. This amendment deals with the second class of changes. In determining the acceptability of revising STS 5.5.13, the staff used the accumulation ofgenerically approved guidance in NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 07, 1995.Licensees may revise the technical specifications to adopt current improved standard technicalspecification format and content provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0 in the context of specific proposed changes.
3.0 TECHNICAL EVALUATION
The NRC staff has reviewed the justification for the proposed TSTF as described in the May 30and June 30 submittals. The detailed evaluation below will support the conclusion that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.3.1 Relocation of the specific American Society for Testing and Materials (ASTM) Standardfrom the Administrative Controls Section of TS to a license-controlled documentThe TSTF proposes to relocate the specific American Society for Testing and Materials (ASTM)Standard for allowable particulate concentration in fuel from the Administrative Controls Section STS 5.5.13 to a license-controlled document, because referencing ASTM Standards in the TS is not required by 10 CFR 50.36. The actual value of allowable particulate concentration in fuel, which is required by 10 CFR 50.36(c), remains in STS 5.5.13.3.2 Revision to Fuel Color Test in STS 5.5.13.a.310 CFR 50.36 requires a DG Fuel Oil Testing Program in the Plant TS. TSTF-374 proposes toprovide more objectivity to the fuel oil testing program's fuel color test by replacing "a clear and bright appearance with proper color" with "a clear and bright appearance with proper color or water and sediment content within limits." Since this revision affords additional detail to the appearance test, it is more restrictive than the current STS 5.5.13.a.13. This revision also meets the requirements of 10 CFR 50.36(c) by defining an "operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier". The North Anna TS currently contain this statement. 3.3 Revision to Bases B 3.8.3 ReferenceOn this basis, the NRC staff concludes that the changes proposed by TSTF-374 areacceptable. This proposed revision updates Bases B 3.8.3 to reference the current ASTM Standards. The proposed changed revises the STS Bases for SR 3.8.3.3 to indicate that the API gravity is tested in accordance with ASTM D287-82 and to provide an additional method (ASTM D4294) for sulfur testing.
4.0 CONCLUSION
The changes proposed by TSTF-374 assure the quality of the diesel fuel will be maintained atstandards that provide high reliability of diesel availability. The NRC staff concludes that the proposed changes by the licensee satisfy the requirements of 10 CFR 50.36(c). On this basis, the NRC staff concludes that the TSSTF-374 changes proposed by licensee are acceptable.The Commission has concluded, based on the considerations discussed above, that: (1) thereis reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and, (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.