ML021980129

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Attachment to 07/16/02 Memo: Dominion'S Editorial Comments on Draft Surry and North Anna Safety Evaluation Report, Naps/Sps
ML021980129
Person / Time
Site: Surry, North Anna  Dominion icon.png
Issue date: 07/16/2002
From: Tabatabai-Yazdi O
NRC/NRR/DRIP/RLEP
To:
NRC/NRR/DRIP/RLEP
Tabatabai O, NRR/DRIP/RLEP, 415-3738
References
Download: ML021980129 (13)
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NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

1. 2.1.2.1 2-3 List of bullets:

This list of bullets is appropriate and applies to both stations. However, the Surry application has an additional bullet that applies only to Surry.

Therefore, the following fifth bullet should be added.

  • Equipment relied on to maintain its pressure-retaining capability in order to maintain adequate intake canal level for design basis events. (Surry only)
2. 2.1.2.2 2-5 List of numbered items:

This list is appropriate and applies to both stations. However, the Surry application has an additional item that applies only to Surry. Therefore, the following fifth item needs to be added for Surry.

5) Equipment relied on to maintain its pressure retaining capability in order to maintain adequate intake canal level for design basis events (Surry only)
3. 2.1.2.3.1 2-6 Last paragraph, last line:

Change first components to systems

4. 2.1.3.2 2-16 Mechanical Components, 2nd paragraph:

Add a finding at the end, such as: The audit team did not identify any discrepancies between the methodology documented and the implementation results.

5. 2.3.1.1.1 2-25 5th paragraph:

Correct reference to Section 2.3.3.10 of the SER for neutron shield tank cooling to reference Section 2.3.3.11.

6. 2.3.1.3.2 2-31 Last paragraph, 2nd sentence:

Correct the reference to Section 2.3.1.1 to read Section 2.3.1.3 which is the Reactor Vessel Internals section for each LRA.

7. 2.3.1.4.2 2-34 4th paragraph, last sentence:

Sentence states, The table providesand a reference to the AMR results section Table 2.3.1-4 does not provide this reference. The reference is actually provided in the last paragraph of Section 2.3.1.4 of the LRA.

8. 2.3.1.5.1 2-35 1st paragraph, last sentence:

Include nickel-based alloys as a corrosion protection (cladding). The tubesheets are clad with inconel.

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NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

9. 2.3.1.5.2 2-37 3rd and 4th paragraph, last sentence each paragraph:

The last sentence states, the table provides a reference to the AMR results section Table 2.3.1-5 does not provide this reference. The reference is actually provided in the last paragraph of Section 2.3.1.5 of the LRA.

10. 2.3.1.5.3 2-37 1st sentence:

The section number in the first sentence should be changed to 2.3.1.5, rather than 2.3.1.4. Section 2.3.1.5 is the LRA section for steam generators.

11. 2.3.3.1 2-51 Last line:

The UFSAR chapters for NAS and SPS are reversed.

12. 2.3.3.1 2-52 1st paragraph:

Section 2.3.2.4 should be changed to Section 2.3.3.1.

13. 2.3.3.12.2 2-83 Last paragraph:

Change CW to PG.

14. 2.3.3.13.1 2-84 1st paragraph, 3rd sentence:

Sentence states, In each LRA Sections 2.3.3.13, the applicant The sentence should be revised to read, In North Anna LRA, Section 2.3.3.10, and the Surry LRA, Section 2.3.3.11, the applicant...

15. 2.3.3.13.2 2-86 3rd paragraph, 1st sentence:

Change CW to AAC.

16. 2.3.3.14.1 2-87 1st paragraph, 2nd and 4th sentences:

Sentences do not include the emergency generator (EG) system for North Anna. The emergency generator (EG) system needs to be added to the list of systems for completeness.

17. 2.3.3.19.2 2-99 Drawing list following the 3rd paragraph:

The North Anna drawing list is incorrect. Delete the existing 3 drawings for North Anna Units 1 and 2, and add two drawings as follows:

Delete: 11715-LRM-079C, Sh. 1 for Unit 1 11715-LRM-092A, Sh. 2 for Unit 1 12050-LRM-092A, Sh. 2 for Unit 2 Add: 11715-LRM-082F, Sh. 1 for Unit 1 12050-LRM-082F, Sh. 2 for Unit 2 Page 2 of 13 LRA-NRC / SER-LRA / Draft-SER-Editorial-Comments-07-16-02

NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

18. 2.3.3.20 2-100 Section 2.3.3.20 of the SER has the wrong LRA Section number 2-101 referenced for containment vacuum. It should reference LRA Section 2-102 2.3.3.17 not Section 2.3.3.20.
19. 2.3.3.20.2 2-101 After 5th paragraph:

The Surry drawing list is incorrect. Delete the Surry Unit 1 & 2 drawing and add the correct drawings.

Delete: 11448-LRM-075G, Sh. 1 for Unit 1 11548-LRM-075E, Sh. 1 for Unit 2 Add: 11448-LRM-085A, Sh. 1 for Unit 1 11448-LRM-085A, Sh. 2 for Unit 1 11548-LRM-085A, Sh. 1 for Unit 2 11548-LRM-085A, Sh. 2 for Unit 2

20. 2.3.3.21 2-102 Section 2.3.3.21 of the SER has the wrong LRA Section number 2-103 referenced for leakage monitoring. It should reference LRA Section 2-104 2.3.3.18 not Section 2.3.3.21.
21. 2.3.3.22 2-104 Section 2.3.3.22 of the SER has the wrong LRA Section number 2-105 referenced for secondary vents. It should reference LRA Section 2-106 2.3.3.19 not Section 2.3.3.22.
22. 2.3.3.23 2-106 Section 2.3.3.23 of the SER has the wrong LRA Section number 2-107 referenced for vacuum priming. It should reference LRA Section 2-108 2.3.3.20 not Section 2.3.3.23.
23. 2.3.3.3 2-57 The UFSAR section references are incorrect. SPS should be Chapter 7.6.1 and NAS should be Chapter 7.7.1.9.
24. 2.3.3.35 2-133 2nd sentence:

Sentence states: The system is further described in Section 11.2.5 of the SPS UFSAR. The sentence should read, The system is further described in Section 9.7 of the SPS UFSAR.

25. 2.3.3.37.1 2-137 Last paragraph: (related to NAS 1/2)

Table 2.3.3-31 does not include fuel oil system. It is not a Fire Protection system component.

Table 2.3.3-31 does not include pressure tank. (It does list tanks and other component groups.)

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NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

26. 2.3.3.37.1 2-138 1st paragraph: (related to SPS1/2)

For Surry, the table number should be 2.3.3-30 not 2.3.3-31.

Table 2.3.3-30 does not include fuel oil system. It is not a Fire Protection system component.

Table 2.3.3-30 does not include pressure tank. (It does list tanks and other component groups.)

2nd paragraph:

Last sentence should identify Table 2.3.3-30 for NAS 1/2 and Table 2.3.3-30 for SPS1/2.

27. 2.3.3.37.1 2-140 1st paragraph:

Table 2.3.3-30 should be Table 2.3.3-31 in the NAS discussion.

28. 2.3.3.4 2-59 Last sentence:

The Surry UFSAR reference is incorrect. It should be Chapter 11.3.1.

29. 2.3.3.5.1 2-62 2nd and 3rd paragraphs:

The reference to Section 2.3.3.5 for each LRA.. is not correct. The SPS LRA section should be changed to 2.3.3.4.

The reference to Table 2.3.3-5 for each LRA is not correct. The SPS LRA table should be changed to Table 2.3.3-4. (this comment also applies to the third paragraph).

Note:

The above comments are also applicable to the following sections:

2.3.3.5.2: 1st, 2nd, 3rd, and 5th paragraphs.

2.3.3.5.3: 1st sentence.

30. 2.3.3.7.1 2-67 3rd Paragraph, 2nd sentence:

This sentence incorrectly states that there are four emergency SW pumps are available under abnormal conditions. There are only 3 diesel-driven emergency SW pumps at Surry. (Reference Surry UFSAR Section 9.9.1.2. )

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NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

31. 2.3.4.6.2 2-161 Listing of drawings:
  • The following listed drawing were not referenced in the LRA for the SD system and should be removed from the list of LRA drawings listed for the SD system:

11715-LRM-070A, Sh. 1 11715-LRM-070A, Sh. 2 11715-LRM-072A, Sh. 1 12050-LRM-070A, Sh. 1 12050-LRM-070A, Sh. 2 12050-LRM-072A, Sh. 1 st nd

32. 2.4.12.1 2-201 1 paragraph, 2 sentence:

Delete the words in Table 2.2-1 since the table does not list the in-scope cranes in the table. They are listed in Section 2.4.12 as stated in the 3rd sentence of this paragraph.

33. 2.4.3.1 2-171 Main Steam Valve House, 1st paragraph, 4th sentence:

Sentence should read The valve house has a roof slab and an intermediate floor slab.

34. 2.4.3.1 2-172 Auxiliary Feed-water Pump House (NAS 1/2), 3rd sentence:

Sentence should read One cubicle houses the two motor-driven auxiliary feed-water pumps and the other cubicle houses one turbine-driven auxiliary feed-water pump.

35. 2.4.5 2-179 Last sentence:

Revise referenced SPS UFSAR Section 9.4.10 to correctly state 9.10.4.

36. 2.4.5 2-179 List of Bullets:

Add the following:

  • Radwaste Facility (Surry plant)
  • Maintenance Building (North Anna plant)

These buildings are added to the scope by the response to RAI 2.3.3.31-2.

37. 2.4.7 2-187 List of structures:

The SPS UFSAR references for the Surry plant are not correct. The Sections should be 6.3.1.3, 8.4.5, 8.5, 9.10.2, 9.10.4, and 10.3.5.

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NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

38. 2.4.7 2-187 List of structures:

Add the following:

  • containment mat sub-surface pump access shaft This structure was added via response to RAI 3.5-1.
39. 2-1 Variou General Comment, Section 2.1:

s In various places throughout Section 2.1, the term non-safety-related quality has been used instead of the defined Dominion term of NSQ or non-safety-related with special quality/regulatory requirements. To avoid potential conflicts of definition, the Dominion terminology needs to be used consistently or the SER needs to define that the term it uses is equivalent to the NSQ definition provided on Page xxii of the SER.

40. 3.3.1.15 3-60 6th paragraph, Detection of Aging Effects:

Change the word AMA to augmented inspection activity.

41. 3.3.1.5 3-18 3rd line from top of page:

In the Chemistry Parameters entry for Main Steam, delete the word hotwell from the description of dissolved oxygen.

42. 3.3.2 3-83 1st sentence, Section A2.0, Programs and Activities, FSAR Supplement:

3-84 The reference to the UFSAR supplement section should be to Chapter 18, not 17 which is the QA Topical Report section.

3rd sentence,

Conclusion:

The reference to the UFSAR supplement section should be to Chapter 18, not 17 which is the QA Topical Report section.

43. 3.3.3.2.2 3-88 List of bullets under Parameters inspected or monitored:

Add the following to the top portion of the list which is applicable to both SPS and NAS:

  • Loss of AC Power
44. 3.3.3.2.4 3-90 Last sentence:

Remove the reference to the BWR plant component - torus structure components.

45. 3.4.3.2 3-133 Item 11 response, last paragraph:

Add the finding, The staff finds this to be acceptable.

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NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

46. 3.4.4.2.1 3-144 3rd paragraph, 2nd sentence:

The reference to Table 4.1.4-1 is incorrect. Change the table number to 3.1.4-1.

47. 3.4.4.2.2 3-145 List of bullets:

Include the following in bulleted list on this page:

  • Examination Category B-P (All pressure-retaining components)
  • Examination Category B-H (Integral attachment for vessels)
48. 3.4.5.2 3-149 1st paragraph on page:

The SER implies that in the future we will be modifying our S/G Inspections AMA to implement the recommendations of GL 97-06. The WCAPs referenced refer to multiple SG types, Therefore, add ,as appropriate, following intends to implement. In this paragraph.

49. 3.4.5.2.1 3-149 Last paragraph:

Add the finding, The staff finds this to be acceptable.

50. 3.5.2.1 3-157 2nd bullet on this page:

The information is correct for North Anna only. For Surry, however, the Containment Spray (CS) nozzles are stainless steel.

51. 3.6.1.1 3-161 2nd paragraph of this section:

With the exception of the CH system, the LRA section numbers are plant specific because Surry does not have a separate HRSS. It is recommended that the two stations be listed separately to clearly identify the applicable LRA sections for each station. Propose the following:

SPS LRA Sections (Systems) 2.3.3.1 Chemical Volume and Control (CH) system 2.3.3.2 Incore Instrumentation (IC) system 2.3.3.3 Reactor Cavity Purification (RL) system 2.3.3.4 Sampling System (SS) system Page 7 of 13 LRA-NRC / SER-LRA / Draft-SER-Editorial-Comments-07-16-02

NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

NAS LRA Sections (Systems) 2.3.3.1 Chemical Volume and Control (CH) system 2.3.3.2 High Radiation Sampling System (HRSS) system 2.3.3.3 Incore Instrumentation (IC) system 2.3.3.4 Refueling Purification (RL) system 2.3.3.5 Sampling System (SS) system

52. 3.6.2.1 3-163 In Section 3.6.2.1:

Summary of Technical Information in the Application for the Open Water Systems, the second paragraph lists the locations of the applicable system descriptions. The list is only for the NAPS references.

It is recommended that the two stations be listed separately to clearly identify the applicable LRA sections for each station. Propose the following:

SPS LRA Sections (Systems) 2.3.4.2 Blowdown (BD) system 2.3.3.5 Circulating Water (CW) system 2.3.3.6 Service Water (SW) system 2.3.3.20 Vacuum Priming (VP) system 2.3.3.21 Ventilation (VS) system NAS LRA Sections (Systems) 2.3.3.21 Heating and Ventilation (HV) 2.3.3.14 Instrument Air (IA) 2.3.3.6 Service Water (SW)

53. 3.6.3.1 3-166 2nd paragraph:

Summary of Technical Information in the Application for the Closed Water Systems, the second paragraph lists the locations of the applicable system descriptions. The list is only for the NAPS references.

It is recommended that the two stations be listed separately to clearly identify the applicable LRA sections for each station. Propose the Page 8 of 13 LRA-NRC / SER-LRA / Draft-SER-Editorial-Comments-07-16-02

NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

following:

SPS LRA Sections (Systems) 2.3.3.7 Bearing Cooling BC) system 2.3.3.8 Component Cooling (CC) system 2.3.3.14 Instrument Air (IA) system 2.3.3.9 Neutron Shield Tank Cooling (NS) system 2.3.3.10 Primary Grade Water (PG) system 2.3.1.1 Reactor Coolant (RC) system 2.3.3.21 Ventilation (VS) system NAS LRA Sections (Systems) 2.3.3.7 Chilled Water (CD) system 2.3.3.8 Component Cooling (CC) system 2.3.3.17 Containment Vacuum (CV) system 2.3.3.21 Heating and Ventilation (HV) system 2.3.3.9 Neutron Shield Tank Cooling (NS) system 2.3.1.1 Reactor Coolant (RC) system

54. 3.6.5.1.1 3-170 1st paragraph of this section:

1st sentence identifies cast iron as a material. This should be deleted since there is no cast iron material for the air and gas systems at Surry or North Anna.

55. 3.6.7.1 3-173 2nd paragraph, needs to be re-written as follows:

Summary of Technical Information in the Application for the Drain and Liquid Processing Systems, the second paragraph lists the locations of the applicable system descriptions. The list is only for the SPS references. It is recommended that the two stations be listed separately to clearly identify the applicable LRA sections for each station. Propose the following:

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NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

SPS LRA Sections (Systems) 2.3.3.22 Boron Recovery (BR) system 2.3.3.23 Drains - Aerated (DA) system 2.3.3.24 Drains - Gaseous (DG) system 2.3.3.25 Plumbing (PL) systems NAS LRA Sections (Systems) 2.3.3.22 Boron Recovery (BR) system 2.3.3.23 Drains - Aerated (DA) system 2.3.3.24 Drains - Building Services (DB) system 2.3.3.25 Drains - Gaseous (DG) system 2.3.3.26 Liquid and Solid Waste (LW) system 2.3.3.27 Radwaste (RW) system

56. 3.6.8.1 3-175 2nd paragraph, needs to be re-written as follows:

Summary of Technical Information in the Application for the Vent and Gaseous Processing Systems, the second paragraph lists the locations of the applicable system descriptions. The list is only for the SPS references. It is recommended that the two stations be listed separately to clearly identify the applicable LRA sections for each station. Propose the following:

SPS LRA Sections (Systems) 2.3.3.26 Gaseous Waste (GW) system 2.3.3.27 Radiation Monitoring (RM) system 2.3.3.28 Vents - Aerated (VA) system 2.3.3.25 Vents - Gaseous (VG) systems NAS LRA Sections (Systems) 2.3.3.28 Post-Accident Hydrogen Removal (HC) system 2.3.3.29 Radiation Monitoring (RM) system 2.3.3.30 Vents - Gaseous (VG) systems Page 10 of 13 LRA-NRC / SER-LRA / Draft-SER-Editorial-Comments-07-16-02

NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

57. 3.6.9.1 3-177 1st paragraph, 1st sentence:

The LRA Section 3.6.9 reference should be Section 3.3.6.9.

2nd paragraph:

The list is only for the SPS references. It is recommended that the two stations be listed separately to clearly identify the applicable LRA sections for each station. Propose the following:

SPS LRA Sections (Systems) 2.3.3.30 Fire Protection (FP) system 2.3.3.31 Hydrogen Gas (HG) system NAS LRA Sections (Systems) 2.3.3.31 Post-Accident Hydrogen Removal (HC) system 2.3.1.1 Reactor Coolant (RC) system: RCP oil collection

58. 3.8.2.1 3-193 Yard Structures:

Add under yard structures at SPS and NAPS the containment mat sub-surface pump access shaft, since this structure was added via RAI 3.5-1.

59. 3.8.2.1 3-193 List of bullets:

Add maintenance building to Miscellaneous Structures - North Anna.

Add radwaste facility to Miscellaneous Structures - Surry.

These structures are included in the scope of miscellaneous structures by the response to RAI 2.3.3.31-2.

60. 3.8.2.2.1 3-197 4th paragraph, 1st Sentence:

The first sentence should read as follows:

For the loss of material aging effect, the applicant identified the following plausible aging mechanisms: (1) aggressive chemical attack, (2) freeze-thaw, (3) elevated temperatures, (4) corrosion of embedded steel, and (5) abrasive erosion and cavitation.

61. 3.8.2.2.2 3-203 Last paragraph, next to last sentence:

Correct references to Section 3.6.1.6. The sentence should read as follows: This commitment made by the applicant is noted in Section Page 11 of 13 LRA-NRC / SER-LRA / Draft-SER-Editorial-Comments-07-16-02

NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

3.3.1.6 of this SER as Confirmatory Action 3.3.1.6.1.

62. 3.8.4.2.1 3-214 Paragraph titled Bronze:

The sentence, Only the Surry RHR pump support bearing plate is made of bronze, is not a correct statement. The paragraph should be reworded as follows: The applicant identified loss of material due to borated water leakage as the only aging effect requiring management for bronze. The Surry RHR pump support bearing plate is the only component made of bronze that is exposed to a boric acid environment. The staff concurs with the applicants finding.

63. 4.1.1 4-1 List of Bullets:

Remove bullet concrete containment pre-stress calculations Table 4.1-1 of the LRA does not identify these as TLAAs for SPS or NAS

64. 4.1.1 4-1 List of Bullets:

Revise bullet containment liner and penetration analyses to containment liner analyses. Containment penetrations are identified as not being a TLAA in Table 4.1-1.

65. 4.2 4-3 1st paragraph, Item (b):

Delete or a steam line break from item (b). The evaluation for PTS bounds several transients including but not limited to a main steam line break.

66. 4.6.2 4-25 1st complete sentence:

Revise 20 design basis earthquake cycles to 30 design basis earthquake cycles to reflect the extrapolation to 60 years of operation.

67. Appendix A A-2 1st reference to October 11, 2001:

Change .and B2.2.9 of North Anna and. to .and B2.2.19 of North Anna and

68. General N/A Several references are made to e-mails as the source of applicants responses. For example: Page 2-178, Section2.4.4.2, 1st paragraph:

Paragraph refers to an e-mail (which is not traceable) on September 24, 2001, in which applicant responded to the staffs questions. The applicants responses to these staff questions are documented in the NRC notes of Telecom Letter dated October 25, 2001.

Shouldnt telecom letter (traceable) be used as a reference?

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NAPS/SPS Draft Safety Evaluation Report Editorial Comments 07/15/2002 Item Section Page Comment No. No. No.

69. General N/A The term commodity is routinely used in the context of the mechanical component groups. References to mechanical commodity groups should be identified and corrected to component groups. For example:

Section 2.3.2.1.1, page 2-26, 2nd paragraph, 2nd sentence:

Sentence states, mechanical component commodity groups. It should state, mechanical component groups (delete the word commodity).

Also replace the word commodity in the last sentence of this paragraph with component.

Recommend a search of the term commodity be performed to address this concern.

Page 13 of 13 LRA-NRC / SER-LRA / Draft-SER-Editorial-Comments-07-16-02

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