ML20203C825

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Proposed Tech Specs Re Allowed Outage Time for PORV Nitrogen Accumulators & Separate Actions for PORV Operability
ML20203C825
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 02/05/1999
From:
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20203C822 List:
References
NUDOCS 9902120266
Download: ML20203C825 (26)
v • d • e


Text

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REACTOR COOLAffT SYSTEM [

t SAFETY AND RFI TFF VALVES - OPERATING l l i l l_ l RF1 TEF VALVES LIMITING CONDmON FOR OPERATION 3.4.3.2- Both power-operated relief valves (PORVs) and their associated block valves shall be  !

OPERABLE.  !

4 i  ;

ii i

.1. APPLICABILITY: MODES 1. 2. and 3.

4 i ACTION:

A. PORV(s): I i

1. With one or both PORV(s) inoperable solely because of excessive seat leakage, within I hour either restore the PORV(s) to OPERABLE status or close the associated block valve (s) with power maintained to the block valve (s); otherwise, 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 HOT SHUTDOWN . l g within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
2. A With one or both PORV(:) inoperable because of (an) inoperable backup nitrogen j supply (ies) within 14 days either restore the PORV(s) backup nitrogen supply (ies) to OPERABLE status or be in 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3 With one or both PORV(s) inoperable due to a malfunction in the PORV sutomatic control system within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore the affected automatic control system (s) to OPERABLE status or place and mairt m the affected PORV(s) in manual control.

4 With one PORV inoperable due to causes ether than those addressed in ACTIONS A.l. A.2 or A.3 above. within I hour either restore the PORV to OPERABLE status or close its associated block valve and remove power from the block valve: restore the PORV to DPERABLE status within the following 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY withm the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN wi;hin the following ,

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. l i With both PORVs inoperable such that ACTIONS A.l. A.2 or A.3 above do not apply, within I hour either restore at least one PORV to OPERABLE status or close

. the associated block valves and remove power from the block valves and be in 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

6. The provisions of Specification 3.0.4 are not applicable.

'. 9902120266 990205 l PDR ADOCK 05000338 i P PDR i

1 NORTH ANNA - UNIT 1 3/4 4-7a Amendment No. 32, !S9, i

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}/L44 REACTOR COOLANT SYSTEM l 1

L BASES i i

b) Mamtaming the mtegrity of the reactor coolant pressure boundary. l i

. 1 c) Manual control of the block valve to (1) unblock an isolated PORV to allow it to be j used for manual control of reactor coolant system pressure (Item a. above L and (2)  !

]i isolate a PORV with excessive seat leakage (Item b, above). l

\

!l j-l di Automatic comrol of PORVs to control RCS pressure. This is a function that reduces l j

'!' challenges to the code safety' valves for overpressurization events. l l

et Manual control of a block valve to isolate a stuck PORV or a PORV which has the l l J potential for spurious opening due to a control system malfunction.  ;

If a PORV is inoperable because of excessive seat leakage. closure of the block valve is

required to restore RCS pressure boundary integrity. Power is maintained to the block valves so that the PORVs will continue to be available for the safety related function of manual RCS

, depressunzation in the event of a steam generator tube rupture. In addition, the automatic pressure

. control capability could be restored by opening the block valves. Therefore, continued operation is allowed.

With one or both PORUS inoperable due to an inoperable backup nitrogen supply, contmued operation for M d> s is allowed provided the normal motive force for the PORVs,i.e.,

the mstrument air system. contmues to be available. Instrument air has a high system reliability, and the likelihood of its bemg unavailable during a demand for PORV operation is low enough to iustify a reasonable length of time (i.e.14 days) to repair the nitrogen system. A4M.', nh

-. -te ,~ wwp4.:.J .:, m .,4 4 c.hka 4.a.4 %w 6 LA a . WLJ 4 ., A b.ap If one or both PORVs are inoperable due to a malfunction in the PORV automatic control n.bn  !

system. the PORV should be placed in manual control to limit the potential for a spurious opening 5""D* i c' the PORV. Closure of the block valves is not required in this case so that the manual function remam> readily available.

If one or both block valves are inoperable. the associated PORV(s) are placed in manual c control to hmit the potential for a spurious PORV opening due to a control system malfunction

- which would not be isolable via the block valve. The time allowed to restore the block valve (s) to

- ! OPERABLE status is based on the remedial action time limits for inoperable PORV control l

systems smce the PORVs are not capable of mitigating an overpressure event when placed in  !

1 i manual control. I Surveillance Requirements provide assurance that the PORVs and block valves can 1 l , ] perform their functions. Specification 4.4.3.2.1 addresses the PORVs, including the backup  :

t i nstrogen supply system, and Specification 4.4.3.2.2 addresses the block valves. The block valves l

[ l l are exempt from the surveillance requirements to cycle the valves when they have been closed to j l comply with the ACTION requirements. This precludes the need to cycle the valves with full

l. p}

. NORTH ANNA - UNIT 1 B 3/4 4 '2a Amendment No. 449, l

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I T20y' l ADMINISTRATIVE CONTROLS Configuration Risk Management Program (continued)

3) Provisions for performing an assessment after entering the LCO Action Statement l for unplanned entry into the LCO Action Statement.

l

4) Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action Statement.
5) Provisions for considering other applicable risk significant contributors such as Level 2 issue and extemal events, qualitatively or quantitatively.

Current risk-informed action statements include: Action 3.8.1.1.b e 7.4.3.2. A.2 l6_4 REPORTING REOUIREMENTS ,

i  !

ROUTINE REPORTS l6.9.1 In addition to the applicable reponing requirements of Title 10, Code of Federal j Regulations. the following reports shall be submitted to the Director of the Regional Office of  ;

Inspection and Enforcement unless otherwise noted. i l

i STARTUP REPORTS

,' 6.9.1.1 A summary report of plant stanup and power escalation testing shall be submitted L following ia) receipt of an operating license. (2) amendment to the license involving a planned

, merease m power level. (3) installation of fuel that has a different design or has been manufactured

by a different fuel supplier and (4) modifications that may have significantly altered the nuclear.

4- thermal. or hydraulic performance of the plant.

6.9.1.2 The startup report shall address each of the tests identified in the FSAR and shall

, melude a description of the measured values of the operating conditions or characteristics obtained b during the test program and a comparison of these values with design predictions and l, specifications. Any corrective actions that were required to obtain satisfactory operation shall also l l be described. Any additional specific details requested in license conditions based on other commitments shall be included in this repon.

i i 6.9.1.3 Stanup repons shall be submitted within (1) 90 days following completion of the

! stanup test program (2) 90 days following resumption or commencement of commercial power i operation, or (3) 9 months following initial criticality, whichever is earliest. If the Stanup Report j

' does not cover all three events (i.e., initial criticality, completion of startup test program, and l resumption or commencement of commercial power operation), supplementary reports shall be ~

submitted at least everythree months until all three events have been completed.

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NORTH ANNA - UNIT 1 6 14 Amendment No. 63,-M4-l

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REACTOR COOLANT SYSTElyf  ;

SAFETY AND RFI TFF VALVES -- OPERATING  !

. RFI TFF VALVES  !

t LIMITING CONDITION FOR OPERATION l a

3.4.3.2 Both power-operated relief valves (PORVs) and their associated block valves shall be  ;

l OPERABLE.

t APPLICABILITY: MODES 1. 2. and 3.

ACTION:  :

' A. PORV(s):

'l. With one or both PORV(s) inoperable sole'ly because of excessive seat leakage.  ;

within I hour either restore the PORV(s) to OPERABLE status or close the. l associated block valve (s) with power' maintained to the block valve (s); otherwise. ]

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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. )

h*-SeJ) 3 With one or both PORV(s) inoperable because of(an) inoperable backup nitrogen i

I supply (ies), within 14 days either restore the PORV(s) backup nitrogen supply (ies) to OPERABLE status or be in HOTSTANDBY 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3 With one or both PORVtsiinoperable due to a malfunction m the PORV automatic control system, within I hour restore the affected automatic control system (s) to OPERABLE status or place and maintain the affected PORV(s) in manual control.

.: With one PORV inoperable due to causes other than those addressed in ACTIONS A.l. A.2 or A.3 above. within I hour either restore the PORV to OPERABLE status or close its associated block valve and remove power from the block valve: restore the PORY to OPERABLE status within the following 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

5. With both PORVs inoperable such that ACTIONS A.I. A.2 or A.3 above do not apply, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore at least one PORV to OPERABLE status or close the associated block valves and remove power from the block valves and be in 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
6. The provisions of Specification 3.0.4 are not applicable.

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' NORTH ANNA - UNIT 2 3/4 4-7a Amendment No. 4M.

V 3LM REACTOR COOLANT SYSTEM ,

B ASES -

L c) Manual control of the block valve to (1) unblock an isolated PORV to allow it to be L used for manual control of reactor coolant system pressure (Item a. above), and (2)

{ isolate a PORV with excessive seat leakage (Item b, above).- i

'd) Automatic control of PORVs to control RCS pressure. This is a function that reduces l challenges to the code safety valves for overpressurization events.

e) Manual control'of a b' lock valve to isolate a stuck PORV or a PORV which has the -

_ potential for spurious opening due to a control system malfunction.

If a PORV is inoperable because of excessive seat leakage, closure of the block valve is required to restore RCS pressure boundary inteFrity. Power is maintained to the block valves so that the PORVs will continue to be available for the safety related function of manual RCS I depressurization in the event of a steam generator tube rupture. In addition. the autematic pressure control capability could be restored by opening the block valves. Therefore, continued operation is allowed.

With one or both PORVs inoperable due to an inoperable backup nitrogen supply. l continued operation for 14 days is allowed provided the normal motive force for the PORVs. i.e.,

the instnament air system. continues to be available. Instrument air has a high system reliability.  ;

and the likelihood of its being unavailable during a demand for PORV operation is low enough to justify a reasonable length of time (i.e.,14 days) to repair the nitrogen system. 4 L.G. ri*.

. ,... N , .o.w) s. 4 .- Ai b L c a. s.A c... 3 9 , 4,s g...w A ,, % ,,y J ..,, , ,w if one or both PORVs are inoperable due to a malfunction in the PORV automatic contrul 4 ., .

system the PORV should be placed in manual control to limit the potential for a spunous o of the PORV. Closure of the block valves is not required in this case so that the manual function remains readily svailable.

1 If one or both block valves are inoperable, the associated PORV(s) are placed in manual control to limit the potential for a spunous PORV opening due to a control system malfunction which would not be isolable via the block valve. The time allowed to restore the block valve (s) to l OPERABLE status is based on the remedial action time limits for inoperable PORV control  :

systems smce the PORVs are not capable of mitigating an overpressure event when placed in j manual control.

l Surveillance Requirements provide assurance that the PORVs and block valves can perform their functions. Specification 4.4.3.2.1 addresses the PORVs including the backup  ;

mtrogen supply system, and Specification 4.4.3.2.2 addresses the block valves. The block valves ,

are exempt from the surveillance requirements to cycle the valves when they have been closed to l comply 'with the ACTION requirements. This precludes the need to cycle the valves with full  ;

system differential pressure or when maintenance is being performed to restore an inoperable 1 PORV to OPERABLE status. I L

i NORTH ANNA - UNIT 2 B 3/4 4'2a Amendment No. 4% <

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l

OS 25 "" y 1 ADMINISTRATIVE CONTROLS t

Configuration Risk Management Program (continued) 7 l

3) Provisions for performing an assessment after entering the LCO Action Statement (  !

for unplanned entry into the LCO Action Statement. )

I 4) Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action Statement.

5) Provisions for considering other applicable risk significant contributors such as  !

Level 2 issue and extemal events, qualitatively or quantitatively.

Current risk-informed action statements include: Action 3.8.1.1.b; 3.4.3. 2. .A.\ 2_

6J REPORTING REOUIREMENTS ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10. Code of Federal Regulations, the following reports shall be submitted to the Director of the Regional Office of Inspection and Enforcement unless otherwise noted.

STARTUP REPORTS ,

6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following (a) receipt of an operating license. (2) amendment to the license involving a planned increase in power level. (3) installation of fuel that has a different design or has been manufactured  !

by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, j thermal or hydraulic performance of the plant.

l l

NORTH ANNA - UNIT 2 6-14d Amendment No. . !! A.-iW-g

.. _ .. . . .-.... .- ~ -. -. -.- - .-.- - -._ .- . ._-. -._

2 Attachment 4 PROPOSED TECHNICAL SPECIFICATION CHANGE INCLUDING A RISK-INFORMED ALLOWED OUTAGE TIME FOR PORV NITROGEN ACCUMULATOR j Proposed Changes Allowed Outage Time for PORV Nitrogen Accumulator jl and Separate Actions for PORV Operability i

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! North Anna Power Station j Units 1 and 2

] Virginia Electric and Power Company 1

7x j

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1 4

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4 Unit 1 I

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REACTOR COOLANT SYSTEM S AFETY AND RELIEF VALVES - OPERATING RELIEF VALVES LIMITING CONDITION FOR OPERATION l 3.4.3.2 Both power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE.

1 I

APPLICABILITY: MODES 1. 2. and 3.

ACTION:

A. PORV(s): ,

1

1. With one or both PORV(s) inoperable solely because of excessive seat leakage, withm I hour either restore the PORV(s) to OPERABLE status or close the associated block valve (s) with power maintained to the block valve (s); otherwise. 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 HOT SHUTDOWN within the following 6 I

hours.

2. (Risk Informed) With one or both PORV(s) inoperable because of(an) inoperable backup nitrogen supply (ies) within 14 days either restore the PORV(s) backup nitrogen supply (ies) to OPERABLE status or be in 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

I

! 3. With one or both PORV(s) inoperable due to a malfunction in the PORV automatic l I

control system. wuhin I hour restore the affected automatic control system (s) to l

l OPER ABLE status or place and maintain the affected PORV(s) in manual control.

4. With one PORV inoperable due to causes other than those addressed in ACTIONS A.I.

l A.2 or A.3 above. within I hour either restore the PORV to OPERABLE status or close l its awociated block valve and remove power from the block valve; restore the PORV to OPERABLE status within the following 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

5. With both PORVs inoperable such that ACTIONS A.I. A.2 or A.3 above do not apply, within I hour either restore at least one PORV to OPERABLE status or close the associated block valves and remove power from the block valves and be in 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 HOT SHUTDOWN within the following 6 '

hours.

6. The provisions of Specification 3.0.4 are not applicable.

NORTH ANNA - UNIT l 3/4 4-7a Amendment No. 32, '89

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l l l REACTOR COOLANT SYSTEM l SAFETY AND RELIEF ALVES - OPERATING l

l RELIEF VALVES l' LIMITING CONDITION FOR OPERATION i

ACTION: (Continued)  :

B. Block Valves:

L . With one block valve inoperable. within I hour either restore the block valve to OPERABLE status or place its associated PORV in manual controh restore the bh>ck valve to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT )

STANDB Y 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

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2. With both block valves inoperable, within I hour either restore the block valves to OPER ABLE status or place the PORVs in manual control: restore at least one block ,

- valve to OPERABLE status within the next hour: restore the remaining inoperable j block valve to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

3. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.4.3.2.1 in addition to the requirements of Specification 4.0.5, each PORV shall be demonstrated OPERABLE:

a. At least once per 31 days by performing a CHANNEL FUNCTIONAL TEST.

excluding valve operation. and

b. At least once per 18 months by: l
1. Operating the PORV through one complete cycle of full travel during MODES 3 or 4. and  !
2. Operating the solenoid air control valves and check valves on the associated accumulators in the PORV control systems through one complete cycle of full travel, and ,
3. Performing a CHANNEL CALIBRATION of the actuation instrumentation.

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c. At least once per 7 days by verifying that the pressure in the PORV nitrogen accumulators is greater than the surveillance limit.

4.4.3.2.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by i operating the valve through one complete cycle of full travel unless the block valve is closed in I order to meet the requirements of ACTION A.4 or A.5 in Specification 3.4.3.2. l l

NORTH ANNA - UNIT I 3/44-7b Amendment No. 439, l l

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REALTOR COOLANT SYSTEM-LOW-TEMPERATURE VERPRESSURE PROTECTION SURVEILLANCE REQUIREMENTS 4.4.9.3 Each PORV shall be demonstrated OPERABLE by:  ;

a. Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation channel, but excluding valve operation. within 31 days prior to entering a condition ,

in which the PORV is required OPERABLE and at least once per 31 days thereafter when the PORV is required OPERABLE.  ;

b. Performance of a CHANNEL CAllBRATION on the PORV actuation channel. at least once per 18 months.
c. ' Verifying the PORV keyswitch is in the Auto position and the PORV isolation  ;

valve is open at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when the PORV is being used for overpressure protection. i l

d. A t least once per 7 days by verifying that the pressure in the PORV nitrogen l accumulators is greater than the surveillance limit.
c. Testing pursuant to Specification 4.0.5. i i

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NORTH ANNA - UNIT 1 3/4 4-32 Amendment No. l' ? '. !"S,

3/4.4 REACTOR COOLANT SYSTEM l

BASES 3/4.4.2 AND 3/4.4.3 SAFETY AND RELIEF VALVES l

The pressurizer code safety valves operate to prevent the RCS from being pressurized j above its Safety Limit of 2735 psig. Each safety valve is designed to relieve 380.000 lbs per hour i of saturated steam at the valve set point. The relief capacity of a single safety valve is adequate to l

relieve any overpressure condition which could occur during hot shutdown. In the event that no - j safety valves are OPERABLE. an operating RHR loop, connected to the RCS, or the power operated relief valves (PORVs) will prhvide overpressure relief capability and will prevent RCS  ;

overpressurization.  ;

Durmg operation all pressurizer code safety valves must be OPERABLE to prevent the RCS from being pressurized above its safety limit of 2735 psig. The combined relief capacity of all of these valves is greater than the maximum surge rate resulting from a complete loss of load assuming no reactor trip until the first Reactor Protective System trip setpoint is reached (i.e.. no credit is taken for a direct reactor trip on the loss ofload) and also assuming no operation of the power operated relief valves or steam dump valves.

Demonstration of the safety valves' lift settings will occur only during shutdown and will be performed in accordance with the provisions of Section XI of the ASME Boiler and Pressure Vessel Code.

The safety valve tolerance requirement for Modes 1-3 is expressed as an average value.

That is. the as-found error (expressed as a positive or negative percentage) of each tested safety valve is summed and divided by the number of valves tested. This average as-found value is compared to the acceptable range of + 2G to - 3G In addition. no single valve is allowed to be outside of: 39.

An average tolerance of + 29 / - 3G was confirmed to be adequate for Modes 1-3 accident analyses. For the overpressure events. the analyses considered several combinations of valve tolerance with the arithmetic average of the three valves' tolerance equal to + 29 (with no valve l outside of 2 39 ). The case of a + 29 tolerance on each of the three valves provided the most j limiting results. The - 3G tolerance is limiting for the DNB acceptance criterion. I The power operated relief valves (PORVs) and pressurizer steam bubble function to relieve '  ;

reactor coolant system (RCS) pressure during all design transients up to and including the design i step load decrease with concurrent operation of the condenser with steam dumps. Operation of the PORVs minimizes the undesirab?e opening of the spring-loaded pressurizer code safety valves.

l Each PORV has a remotely operated block valve supplied from emergency power to provide j l

l isolation capability should a relief valve become inoperable due to-l l

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1 NORTH ANNA - UNIT I B 3/4 4-2 Amendment No. 32 ! *!,199, S.f, it t 71. .C.

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3/4.4' ' REACTOR COOLANT SYSTEM  !

BASES i

l a) seat leakage, or.-

f b) ' a mechanical or control system problem which results in either the valve sticking open - I or the potential for a spunous opemng of the valve.  ;

The OPERABILITY of the PORVs and block valves is determined on the basis of their  !

being capable of performing the following functions: .

i a) ' Manual control of PORVs to control reactor coolant system pressure. This function is  ;

assumed for mitigation of the steam generator tube rupture accident and is therefore  !

considered a safety function. -

b) Maintaining the integrity of the reactor coolant pressure boundary. This function is related to controlling identified leakage and ensuring the ability to detect unidentified j reactor coolant pressure boundary leakage, c) Manual control of the block valve to (1) unblock an isolated PORV to allow it to be  ;

used for manual control of reactor coolant system pressure (Item a, above), and (2) iso-late s PORV with excessive seat leakage (Item b, above).  !

d) ' Automatic control of PORVs to control reactor coolant system pressure. This is a j function that reduces challenges to the code safety valves for overpressurization events. ]

e) Manual control of a block valve to isolate a stuck PORV or a PORV which has the potential for spurious opening due to a control system' malfunction.

If a PORV is inoperable because of excessive seat leakage, closure of the block valve is required to restore RCS pressure boundary integrity. Power is maintained to the block valves so that the PORVs will continue to be available for the safety related function of manual RCS depressurization in the event of a steam generator tube rupture. In addition, the automatic pressure control capability could be restored by opening the block valves. Therefore, continued operation is allowed.

With one or both PORVs inoperable due to an inoperable backup nitrogen supply, continued operation for 14 days is allowed provided the normal motive force for the PORVs, i.e.,

the instrument air system, continues to be available. Instrument air has a high system reliability, and the likelihood ofits being unavailable during a demand for PORV operation is low enough to justify a reasonable length of time (i.e.,14 days) to repair the nitrogen system. A Configuration l

Risk Management Program (CRMP) defined in Administrative Control Section 6.8,4.g is l

implemented to evaluate risk associated with an inoperable backup nitrogen supply.

1 NORTil ANNA - UNIT 1 - B 3/4 4-2a Amendment No.1 S9, 2^^,

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3/4.4 REACTOR COOLANT SYSTEM BASES I

If one or both PORVs are inoperable due to a malfunction in the PORV automatic control l

system, the PORV should be placed in manual control to limit the potential for a spurious opening j of the PORV. Closure of the block valves is not required in this case so that the manual function remains readily available.

- If one or both block valves are inoperable, the associated PORV(s) are placed in manual control to limit the potential for a spurious PORV opening due to a control system malfunction ,

which would not be isolable via the clock valve. The time allowed to restore the block valve (s) to  !

OPERABLE status is based on the remedial action time limits for inoperable PORV control l

systems since the PORVs are not capable of mitigating an overpressure event when placed in l manual control. l Surveillance Requirements provide the assurance that the PORVs and block valves can  !

perform their functions. Specification 4.4.3.2.1 addresses the PORVs, including the backup j nitrogen supply system, and Specification 4.4.3.2.2 addresses the block valves. The block valves .  ;

are exempt from the surveillance requirements to cycle the valves when they have been closed to  !

comply with the ACTION requirements. This precludes the need to cycle the valves with full I system differential pressure or when maintenance is being performed to restore an inoperable PORV to operable status.

Surveillance limits are established for the pressure in the backup nitrogen accumulators to ensure there is adequate motive power for the PORVs to cope with a steam generator tube rupture coincident with loss of the containment instrument air system.

Surveillance Requirement 4.4.3.2.1.b provides for the testing of the mechanical and electrical aspects of the PORVs and their associated control systems. This testing is performed in MODE 3 or 4 to limit the potential of spurious or inadvertent opening of a PORV during power operation while maintaining a temperature and pressure environment which is representative of power operating conditions.

3/4.4.4 PRESSURIZER The limit on the maximum water volume in the pressurizer assures that the parameter is maintained within the normal steady state envelope of operation assumed in the SAR. The limit is consistent with the initial SAR assumptions. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> periodic surveillance is sufficient to ensure that the parameter is restored to within its limit following expected transient operation. The I maximum water volume also ensures that a steam bubble is formed and thus the RCS is not a hydraulically solid system.

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g NORTH ANNA - UNIT 1 B 3/4 4-2b Amendment No.  !

yr - ,,ip-.- , -w-- .yp4 r. .m, p - , - - - . g -.w-

l t I REACTOR COOLANT SYSTEM ,

I BASES Low-Temperature Overpressure Protection The OPERABILITY of two PORVs or an RCS vent opening of greater than 2.07 square inches ensures that the RCS will be protected from pressure transients which could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RCS cold legs are less than or j equal to 235 F. Either PORV has adequate relieving capability to protect the RCS from i overpressurization when the transient is limited to either (1) the start of an idle RCP with the  !

secondary water temperature of the steam generator less than or equal to 50 F above the RCS cold  !

leg temperatures or (2) the start of a charging pump and its injection into a water-solid RCS. i i

Automatic or passive low temperature overpressure protection (LTOP) is required whenever any RCS cold leg temperature is less than 235 F. This temperature is the water i

temperature corresponding to a metal temperature of at least the limiting RTNDT + 50 F +

instrument uncertainty. Ahove 235 F administrative controlis adequate protection to ensure the limits of the heatup curve (Figure 3.4-2) and the cooldown curve (Figure 3.4-3) are not violated.

The concept of requiring automatic LTOP at the lower end, and administrative control at the upper end. of the Appendix G curves is further discussed in NRC Generie Letter 88-11.

Surveillance limits are established for the pressure in the backup nitrogen accumulators to ensure there is adequate motive power for the PORVs to cope with an inadvertent start of a high head safety injection pump in a water solid condition, allowing adequate time for the operators to respond to terminate the event.

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l NORTH ANNA - UNIT I B 3/4 4-8 Amendment No. ' 1, ' 17, ! ?O, 39,

i l ADMINISTRATIVE CONTROLS l l

Configuration Risk Management Program (continued)  !

3) Provisions for performing an assessment after entering the LCO Action Statement -

for unplanned entry into the LCO Action Statement. '

4) Provisions for assessing the need for additional actions after the discovery of .

additional equipment out of service conditions while in the LCO Action Statement. j i

5) Provisions for considering 'other applicable risk significant contributors such as i Level 2 issue and external events, qualitatively or quantitatively. )

Current risk-informed action statements include: Action 3.8.1.1.b; 3.4.3.2.A.2 l l

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61 REPORTING REOUIREMENTS l ROUTINE REPORTS 6.9.1 In addition to the applicable reportmg regmrements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Director of the Regional Office of' Inspection and Enforcement unless otherwise noted.

STARTUP REPORTS 6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following (a) receipt of an operating license, (2) amendment to the license involving a planned increase in power level. (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. -

6.9.l.2 The startup report shall address each of the tests identified in the FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also j be described. Any additional specific details requested in license conditions based on other

. commitments shall be included in this report.

6.9.l.3 Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest. If the Startup Report does not cover all three events (i.e., initial criticality, completion of startup test program, and ,

resumption or commencement of commercial power' operation), supplementary reports shall be submitted at least every three months until all three events have been completed.

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NORTH ANNA- UNIT l- 6-14 Amendment No. 53,214  !

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REACTOR COOLANT SYSTEM SAFETY AND RELIEF VAI.VES - OPERATING RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.3.2 Both power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE. j APPLICABILITY: MODES 1,2. and 3.

l ACTION: 1 A. PORV(s):

1. With one or both PORV(s) inoperable solely because of excessive seat leakage. within I hour either restore the PORV(s) to OPERABLE status or close the associated block valve (s) with power maintained to the block s alve(s); otherwise, be in at least HOT l 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 MOT SHUTDOWN within the following 6

{

hours.  ;

2. (Risk Informed) With one or both PORV(s) inoperable because of (an) inoperable backup nitrogen supply (ies). within 14 days either restore the PORV(s) backup  !

nitrogen supply (ies) to OPERABLE status or be in HOT STANDBY within the next 6 l hours and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. I

3. With one or both PORV(s) inoperable due to a malfunction in the PORV automatic j control system. within I hour restore the affected automatic control system (s) to l

OPERABLE status or place and maintain the affected PORV(s) in manual control.

4.- With one PORV inoperable due to causes other than those addressed in ACTIONS A.l.

A.2 or A.3 above. within I hour either restore the PORV to OPERABLE status or close 1

its associated block valve and remove power from the block valve; restore the PORV l to OPERABLE status within the following 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY within i the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

5. With both PORVs inoperable such that ACTIONS A.1, A.2 or A.3 above do not apply, j within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore at least one PORV to OPERABLE status or close the associated block valves and remove power from the block valves and be in 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
6. The provisions of Specification 3.0.4 are not applicable.

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t NORTH ANNA - UNIT 2 3/4 4-7a Amendment No. 4M, 1

I REACTOR COOLANT SYSTEM SAFETY AND RELIEF VALVES - OPERATING I RELIEF VALVE _S_

LIMITING CONDITION FOR OPERATION '

ACTION:(Continued) i B. Block Valves: I

1. With one block valve inoperable, within I hour either restore the block valve to  !

OPERABLE status or place its associated PORV in manual control: restore the I block valve to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY l 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2. With both block valves inoperable, within I hour either restore the block valves to .

OPERABLE status or place the PORVs in manual control: restore at least one block  :

valve to OPERABLE status within the next hour: restore the remaining inoperaW {

block valve to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANu 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. l

3. The provisions of Specification 3.0.4 are not applicable.

! SURVEILLANCE REQUIREMENTS 4.4.3.2.1 In addition to the requirements of Specification 4.0.5. each PORV shall be  :

demonstrated OPERABLE:

l a. At least once per 31 days by performing a CHANNEL FUNCTIONAL TEST, excluding valve operation, and

b. At least once per 18 months by:

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1.- Operating the PORV through one complete cycle of full travel during MODES 3 l or 4. and i

2. Operating the solenoid air control valves and check valves on the associated accumulators in the PORV control systems through one complete cycle of full

( travel. and i 3. Performing a CHANNEL CAllBRATION of the actuation instrumentation.

c. At least once per 7 days be verifying that the pressure in the PORV ritrogen accumulators is greater than the surveillance limit.

4.4.3.2.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by  ;

operating the valve through one complete cycle of full travel unless the block valve is closed in order to meet the requirements of ACTION A.4 or A.5 in Specification 3A3.2. l 1

NORTH ANNA - UNIT 2 3/4 4-7b Amendment No. 4M,

. . .. . .-.~ . . . . . = . - . .- .. . - . . .. . ...

REACTOR COOLANT SYSTEM i.

l LOW-TEMPER ATURE OVERPRESSURE PROTECTION SURVEILLANCE REQUIREMENTS 4.4.9.3 Each PORV shall be demonstrated OPERABLE by:  ;

a. Performance of a CHANNEL FUNCTIONALTEST on the PORV actuation channel. ,

but excluding valve operation, within 31 days prior to entering a condition in which  ;

the PORV is required OPERABLE and at least once per 31 days thereafter when the '  :

PORV is required OPERABLE.

b. Performance of a CHANNEL CALIBRATION on the PORV actuation channel. at ,

least once per 18 months.

c. Verifying the PORV keyswitch is in the AUTO position and the PORV isolation valve is open at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when the PORV is being used for overpressure i protection.
d. At least once per 7 days by verifying that the pressure in the PORV nitrogen accumulators is greater than the surveillance limit.
e. Testing pursuant to Specification 4.0.5 1 l

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NORTH ANNA - UNIT 2 3/4 4-31 Amendment No. 4-70,

1 REACTOR COOLANT SYSTEM BASES 3/4.4.2 AND 3/4.4.3 SAFETY AND RELIEF VALVES The pressurizer code safety valves operate to prevent the RCS from being pressurized above its Safety Limit of 2735 psig. Each safety valve is designed to relieve 380.000 lbs per hour ,

of saturated steam at the valve set point. The relief capacity of a single safety valve is adequate to relieve any overpressure condition which could occur during hot shutdown. In the event that no safety valves are OPERABLE, an operating RHR loop, connected to the RCS, or the power operated relief valves (PORVs) will provide overpressure relief capability and will prevent RCS overpressurization.

During operation, all pressurizer code safety valves must be OPERABLE to prevent the RCS from being pressurized above its safety limit of 2735 psig. The combined relief capacity of all of these valves is greater than the maximum surge rate resulting from a complete loss ofload assuming no reactor trip until the first Reactor Protective System trip setpoint is reached (i.e., no credit is taken for a direct reactor trip on the loss of load) and also assuming no operation of the power operated relief valves or steam dump valves.

Demonstration of the safety valves' lift settings will occur only during shutdown and will be performed in accordance with the provisions of Section XI of the ASME Boiler and Pressure Vessel Code.

The safety valve tolerance requirement for Modes 1-3 is expressed as an average value.

That is. the as-found error (expressed as a positive or negative percentage) of each tested safety valve is summed and divided by the number of valves tested. This average as-found value is compared to the acceptable range of + 27c to - 37c. In addition. no single valve is allowed to be  ;

outside of 3 7< . I An average tolerance of + 27c /- 37c was confirmed to be adequate for Modes 1-3 accident analyses. For the overpressure events, the analyses considered several combinations of valve tolerance with the arithmetic average of the three valves' tolerance equal to + 27c (with no valve outside of 2 37c). The case of a + 27c tolerance on each of the three valves provided the most limiting results. The - 37c tolerance is limiting for the DNB acceptance criterion.

The power operated relief valves (PORVs) and pressurizer steam bubble function to relieve reactor coolant system (RCS) pressure during all design transients up to and including the design step load decrease with concurrent operation of the mmicmer with steam dumps. Operation of the PORVs minimizes the undesirable opening of th; :ded pressurizer code safety valves.

Each PORV has a remotely operated block valve s , , im emergency power to provide l isolation capability should a relief valve become inoper. ue to:

l NORTH ANNA - UNIT 2 B 3/4 4-2 Amendment No.121 '70. !S!,

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3/4.4 REACTOR COOLANT SYSTEM I

BASES l l

a) seat leakage, or b) a mechanical or control system problem which results in either the valve sticking open or the potential for a spurious opening of the valve.

The OPERABILITY of the PORVs and block valves is determined on the basis of their being capable of performing the following functions:

a) Manual control of PORVs to control reactor coolant system pressure. This function is assumed for mitigation of the steam generator tube rupture accident and is therefore i considered a safety function.

b) Maintaining the integrity of the reactor coolant pressure boundary. This function is ]

related to controlling identified leakage and ensuring the ability to detect unidentified reactor coolant pressure boundary leakage. l I

c) Manual control of the block valve to (1) unblock an isolated PORV to allow it to be used for manual control of reactor coolant system pressure (Item a, above), and (2) isolate a PORV with excessive seat leakage (Item b, above).

d) Automatic control of PORVs to control reactor coolant system pressure. This is a l function that reduces challenges to the code safety valves for overpressurization events.

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e) Manual control of a block valve to isolate a stuck PORV or a PORV which has the potential for spurious opening due to a control system malfunction. ]

l If a PORV is inoperable because of excessive seat leakage, closure of the block valve is )

required to restore RCS pressure boundary integrity. Power is maintained to the block valves so I that the PORVs will continue to be available for the safety related function of manual RCS i depressurization in the event of a steam generator tube rupture. In addition, the automatic pressure i control capability could be restored by opening the block valves. Therefore, continued operation is allowed.

With one or both PORVs inoperable due to an inoperable backup nitrogen supply,  ;

continued operation for 14 days is allowed provide.d the normal motive force for the PORVs, i.e., i the instrument air system, continues to be available. Instrument air has a high system reliability, and the likelihood of its being unavailable during a demand for PORV operation is low enough to justify a reasonable length of time (i.e.,14 days) to repair the nitrogen system. A Configuration Risk Management Program (CRMP) defined in Administrative Control Section 6.8.4.g is implemented to evaluate risk associated with an inoperable backup nitrogen supply.

If one or both PORVs are inoperable due to a malfunction in the PORV automatic control system, the PORV should be placed in manual control to limit the potential for a spurious opening NORTH ANNA - UNIT 2 B 3/4 4-2a Amendment No. 170,181,

3/4.4 REACTOR COOLANT SYSTEM BASES of the PORV. Closure of the block valves is not required in this case so that the manual function remains readily available.

If one or both block valves are inoperable, the associated PORV(s) are placed in manual control to limit the potential for a spurious PORV opening due to a control system malfunction which would not be isolable via the block valve. The time allowed to restore the block valve (s) to OPERABLE status is based on the remedial action time limits for inoperable PORV control systems since the PORVs are not capable of mitigating an overpressure event when placed in manual control.

Surveillance Requirements provide the assurance that the PORVs u.e Lck valves can perform their functions. Specification 4.4.3.2.1 addresses the PORVs, including the backup nitrogen supply system, and Specification 4.4.3.2.2 addresses the block valves. The block valves are exempt from the surveillance requirements to cycle the valves when they have been closed to comply with the ACTION requirements. This precludes the need to cycle the valves with full system differential pressure or when maintenance is being performed to restore an inoperable PORV to OPERABLE status.

Surveillance limits are established for the pressure in the backup nitrogen accumulators to ensure there is adequate motive power for the PORVs to cope with a steam generator tube rupture coincident with loss of the containment instrument air system.

Surveillance Requirement 4.4.3.2.1.b provides for the testing of the mechanical and electrical aspects of the PORVs and their associated control systems. This testing is performed in MODE 3 or 4 to limk the potential of spurious or inadvertent opening of a PORV during power ,

operation while maintairng a temperature and pressure environment which is representative of l power operating conditions. I 3/4.4.4 PRESSURIZER The limit on the maximum water volume in the pressurizer assures that the parameter is maintained within the normal steady state envelope of operation assumed in the S AR. The limit is consistent with the initial SAR assumptions.The 12-hour periodic surveillance is sufficient to ensure that the parameter is restored to within its limit iollowing expected transient operation. The maximum water volume also ensures that a steam bubble is formed and thus the RCS is not a hydraulically solid system. The requirement that a minimum number of pressurizer heaters be  ;

OPERABLE ensures that the plant will be able to establish natural circulation.  !

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NORTIl ANNA - UNIT 2 B 3/4 4-2b Amendment No.

REAC10R COOLANT SYSTEM BASES Low-Temperature Overpressure Protection The OPERABILITY of two PORVs or an RCS vent opening of greater than 2.07 square inches ensures that the RCS will be protected from pressure transients which could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RCS cold legs are less than or equal to 270 F. Either PORV has adequate relieving capability to protect the RCS from overpressurization when the transient is limited to either (1) the start of an idle RCP with the secondary water temperature of the steam generator less than or equal to 50 F above the RCS cold leg temperatures or (2) the start of a charging pump and its injection into a water-solid RCS.

Automatic or passive low temperature overpressure protection (LTOP) is required whenever any RCS cold leg temperature is less than 270"F. This temperature is the water temperature corresponding to a metal temperature of at least the limiting RTNDT + 50 F +

instrument uncertainty. Above 270 F administrative control is adequate protection to ensure the limits of the heatup curve (Figure 3.4-2) and the coo!down curve (Figure 3.4-3) are not violated.

The concept of requiring automatic LTOP at the lower end, and administrative control at the upper end. of the Appendix G curves is further discussed in NRC Generic Letter 88-11.

Surveillance limits are established for the pressure in the backup nitrogen accumulators to ensure there is adequate motive power for the PORVs to cope with an inadvertent start of a high head safety injection pump in a water solid condition, allowing adequate time for the operators to respond to terminate the event.

3/4.4.10 STRUCTUR AL INTEGRITY 3/4 4.10.1 ASME CODE CLASS 1. 2 and 3 COMPONENTS The inspection programs for ASME Code Class I,2 and 3 Reactor Coolant System components ensure that the structural integrity of these components will be maintained at an acceptable level throughout the life of the plant. To the extent applicable, the inspection program for components is in compliance with Section XI of the ASME Boiler and Pressure Vessel Code.

NORTH ANNA - UNIT 2 B 3/4 4-8 Amendment No. "9, !?0,

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-f ADMINISTRATIVE CONTROLS -

Configuration Risk Management Program (continued)  !

3) Provisions for performing an assessment after entering the LCO Action Statement  !

for unplanned entry into the LCO Action Statement.

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4) Provisions for assessing the need for additional actions after the discovery of  !

additional equipment out of service conditions while in the LCO Action Statement. l t

5) Provisions for considering other applicable risk significant contributors such as i

' Level 2 issue and external events, qualitatively or quantitatively, f

Current risk-informed action statements include: Action 3.8.1.1.b; 3.4.3.2.A.2 I l

i M REPORTING REOUIREMENTS '

i ROUTINE REPORTS  !

l 6.9.1 in addition to the applicable reporting requirements of Title 10, Code of Federal l Regulations, the following reports shall be submitted to the Director of the Regional Office of  ;

inspection and Enforcement unless otherwise noted, j STARTUP REPORTS 6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following (a) receipt of an operating license,(2) amendment to the license involving a planned increase in power level,(3) installation of fuel that has a different design or has been manufactured  !

by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, [

thermal. or hydraulic performance of the plant.

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, . NORTH ANNA.-. UNIT 2 6-14d Amendment No. A7,1li,195,  !

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