ML021970004
| ML021970004 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 02/01/2002 |
| From: | Christian D Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 01-685A, LR/MWH R0 | |
| Download: ML021970004 (9) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 1, 2002 United States Nuclear Regulatory Commission Serial No.:
01-685A Attention: Document Control Desk LR/MWH RO Washington, DC 20555-0001 Docket Nos.:
50-280/281 50-338/339 License Nos.: DPR-32/37 NPF-4/7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY AND NORTH ANNA POWER STATIONS UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATIONS In an October 22, 2001 letter, the NRC requested additional information regarding the license renewal applications (LRAs) for Surry and North Anna Power Stations. The attachment to this letter contains the response to Request for Additional Information (RAI) 3.6-1.
Should you have any questions regarding this submittal, please contact Mr. J. E.
Wroniewicz at (804) 273-2186.
Very truly yours, David A. Christian Senior Vice President - Nuclear Operations and Chief Nuclear Officer Attachment Commitments made in this letter: None A
0#66Q1
Serial No.: 01-685A SPS/NAPS LR - Response to RAI cc page 1 of 4 cc:
U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, GA 30303-8931 Mr. M. J. Morgan NRC Senior Resident Inspector North Anna Power Station Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station Mr. J. E. Reasor, Jr.
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
Suite 300 Glen Allen, VA 23060 Ms. Ellie Irons, EIR Program Manager Virginia Dept. of Environmental Quality 629 East Main St., 6th FI Richmond, VA 23219 Mr. David Paylor, Program Coordinator Virginia Dept. of Environmental Quality P.O. Box 10009 Richmond, VA 23240-0009 Mr. Joe Hassell, Environmental Manager Virginia Dept. of Environmental Quality Water Division P.O. Box 10009 Richmond, VA 23240-0009 Mr. Gerard Seely, Jr., Director Virginia Dept. of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060
Serial No.: 01-685A SPS/NAPS LR - Response to RAI cc page 2 of 4 Mr. Gregory Clayton, Regional Director Virginia Dept. of Environmental Quality Northern Virginia Regional Office 13901 Crown Ct.
Woodbridge, VA 22193 Mr. Frank Fulgham, Program Manager Virginia Dept. of Agriculture & Consumer Services Office of Plant & Pest Services 1100 Bank St.
Richmond, VA 23219 Mr. David Brickley, Agency Director Virginia Dept. of Conservation & Recreation 203 Governor St.
Richmond, VA 23219 Mr. William Woodfin, Director Virginia Dept. of Game & Inland Fisheries 4010 West Broad St.
Richmond, VA 23230 Mr. Robert Hicks, Director Virginia Dept. of Health Office of Environmental Health Services 1500 East Main St., Room 115 Richmond, VA 23219 Ms. Kathleen S. Kilpatrick, Director Virginia Dept. of Historic Resources State Historic Preservation Office 2801 Kensington Ave.
Richmond, VA 23221 Dr. Ethel Eaton, Archeologist Senior Virginia Dept. of Historic Resources State Historic Preservation Office 2801 Kensington Ave.
Richmond, VA 23221
Serial No.: 01-685A SPS/NAPS LR - Response to RAI cc page 3 of 4 Mr. Robert W. Grabb, Assistant Commissioner Virginia Marine Resources Commission 2600 Washington Ave.
Newport News, VA 23607 Dr. John Olney, Associate Professor Virginia Institute of Marine Science School of Marine Science Gloucester Point, VA 23062 Mr. John Simkins Virginia Dept. of Transportation Environmental Division 1401 East Broad St.
Richmond, VA 23219 Mr. Robert Burnley Virginia Economic Development Partnership 901 East Byrd St.
Richmond, VA 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Energy Regulation 1300 East Main St., 4th Fl., Tyler Bldg.
Richmond, VA 23219 Mr. Michael Cline, State Coordinator Commonwealth of Virginia Department of Emergency Management 10501 Trade Rd.
Richmond, VA 23236-3713 Mr. Terry Lewis, County Administrator P.O. Box 65 Surry, VA 23883 Mr. Lee Lintecum Louisa County Administrator P.O. Box 160 Louisa, VA 23093
Serial No.: 01-685A SPS/NAPS LR - Response to RAI cc page 4 of 4 Mr. Douglas C. Walker Acting Spotsylvania County Administrator P.O. Box 99 Spotsylvania, VA 22553 Ms. Brenda G. Bailey, County Administrator P.O. Box 11 Orange, VA 22960 Chairman Reeva Tilley Virginia Council on Indians P.O. Box 1475 Richmond, VA 23218 Mr. Don Lillywhite, Director Economics Information Services Virginia Employment Commission State Data Center 703 East Main St., Room 213 Richmond, VA 23219 Mr. Alan Zoellner Government Information Department Swem Library College of William and Mary Landrum Dr.
P.O. Box 8794 Williamsburg, VA 23187-8794 Mr. Walter Newsome Government Information Resources Alderman Library University of Virginia 160 McCormick Rd.
P.O. Box 400154 Charlottesville, VA 22904-4154
Serial No.: 01-685A SPS/NAPS LR - Response to RAI COMMONWEALTH OF VIRGINIA
) )
COUNTY OF HENRICO
)
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by David A. Christian who is Senior Vice President and Chief Nuclear Officer of Virginia Electric and Power Company.
He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this I
- day of I 2001.
My Commission Expires: Z'3L *4 Notary Public (SEAL)
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-685A Attachment Page 1 of 3 Attachment License Renewal - Response to RAI Serial No.01-685 Response to Request for Additional Information Dated October 22, 2001 Surry and North Anna Power Stations, Units 1 and 2 License Renewal Applications RAI 3.6-1 Virginia Electric and Power Company (Dominion)
Docket Nos. 50-280/281 50-338/339 Serial No.: 01 -685A Attachment Page 2 of 3 Section 3.6, "AMing Management of Electrical and Instrumentation and Controls" RAI 3.6-1:
In response to the staff's request for the applicant to management aging of non-EQ insulated power, instrumentation, and control cables and connectors, as documented in a letter dated June 17, 2001, the applicant commits to a visual inspection of representative samples of accessible insulated power, instrumentation, and control cables and connectors. Visual inspection alone, however, will not necessarily detect reduced insulation resistance (IR) levels in cable insulation before the intended function is lost. Exposure of electrical cables to adverse localized environments caused by heat or radiation can result in reduced IR.
A reduction in IR will cause an increase in leakage currents between conductors and from individual conductors to ground, and is a concern for circuits with sensitive, low level signals such as radiation and nuclear instrumentation since it may contribute to inaccuracies in the instrument loop. Because low level signal instrumentation circuits may operate with signals that are normally in the low milliamp range or less, they can be affected by extremely low levels of leakage current. These low levels of leakage current may affect instrument loop accuracy before the adverse localized environment can cause changes that are visually detectable. Routine calibration tests performed as part of the plant surveillance test program can be used to identify the potential existence of this aging degradation.
The staff is not convinced that aging of these cables will initially occur on the outer casing resulting in sufficient damage such that visual inspection will be effective in detecting the degradation before IR losses lead to a loss in intended function.
Therefore, the applicant is asked to provide a technical justification that will demonstrate that visual inspections will be effective in detecting damage before current leakage can affect instrument loop accuracy, or provide a description of an AMA that will demonstrate that the effects of aging will be managed such that the intended function will be maintained consistent with the current licensing basis for the period of extended operation.
Dominion Response:
Although Dominion aging management reviews have determined that there are no applicable aging effects for non-EQ cables that require aging management, in response to RAI 3.6.2-1 Dominion credited an inspection program for the non-EQ cables located in areas that have potential adverse localized environments, such as heat, radiation, or moisture. This program has been requested by the NRC staff to provide reasonable assurance that these cables will not lose the ability to perform their intended function in the future due to aging effects resulting from the possible creation of adverse localized environments.
Adverse localized environments caused by heat or radiation have the potential to produce reduced insulation resistance (IR).
However, since IR-sensitive circuits operate with currents in the milli-ampere range or less, heat generated in the conductor
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-685A Attachment Page 3 of 3 is insufficient to cause cable degradation from internal sources. Degradation from externally applied stressors of heat or radiation would have to affect the conductor insulation to cause a reduction of insulation resistance.
External degradation of the cable jacket would likely be detected by visual inspection prior to loss of cable intended function.
A review of Dominion operating experience indicates that no instrument cable failures have occurred due to aging and that visual inspection would be effective in detecting cable degradation before any loss of intended function. A review of other utility license renewal SERs indicates acceptance of this approach (e.g., ANO Unit 1, Duke-Oconee, FP&L-Turkey Point [draft], and Southern-Hatch).
In addition, the Electrical Cable and Terminations Aging Management Guideline, SAND96-0344, concludes in Section 1.4 that "... reliance on visual inspection techniques for the assessment of low-voltage cable and termination aging appears warranted since these techniques are effective at identifying degraded cables." An industry operating experience review and a literature search, including the SAND96-0344 report, did not provide any supporting information for the NRC staff concern.
Therefore, the Non-EQ Cable Monitoring Aging Management Activity, as described in response to RAI 3.6.2-1, will provide reasonable assurance through visual inspection that instrument cables that are sensitive to reduced insulation resistance will maintain their intended functions during the period of extended operation.