ML063110195

Request for Additional Information (RAI) Regarding the Steam Generator Tube Integrity Technical Specification Amendment

ML063110195
Person / Time
Site:	Surry
Issue date:	11/06/2006
From:	Siva Lingam NRC/NRR/ADRO/DORL/LPLII-1
To:	Christian D Virginia Electric & Power Co (VEPCO)
Lingam, Siva NRR/DORL 415-1564
References
TAC MD2097, TAC MD2098
Download: ML063110195 (5)

Text

November 6, 2006 Mr. David A. Christian Senior Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

SURRY POWER STATION, UNIT NOS. 1 AND 2, REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING THE STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT (TAC NOS. MD2097 AND MD2098)

Dear Mr. Christian:

By letter dated May 26, 2006, Virginia Electric and Power Company (the licensee) submitted a license amendment regarding steam generator (SG) tube integrity Technical Specifications (TSs) for Surry Power Station, Unit Nos. 1 and 2. The proposed license amendment will revise the requirements in the TSs related to SG tube integrity consistent with Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF), Standard Technical Specification Change Traveler, TSTF-449, Steam Generator Tube Integrity, Revision 4. The NRC staff is reviewing the submittal and has determined that additional information is required to complete its evaluation.

The NRC staffs RAI is enclosed. The licensee is requested to provide a response to the RAI within 30 days.

Sincerely,

/RA/

Siva P. Lingam, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281

Enclosure:

RAI cc w/encl: See next page

ML063110195 NRR-088 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/DCI/CSGB NRR/LPL2-1/BC NAME SLingam SLL for MOBrien AHiser EMarinos DATE 11/2/06 10/16/06 10/20/06 11/6/06 REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT SURRY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-280 AND 50-281

1. Please discuss your plans to make the language in proposed Technical Specification (TS) Sections 3.1.C.2.b and 3.1.H.3 consistent with the language used in the associated bases sections.

2. In proposed Bases Sections 3.1.C.2.b and 3.1.C.3, and Surveillance Requirement (SR) 4.13.A, the term "unit" is used, however, in proposed Bases Section 3.1.H.3 the term "plant" is used. Please discuss your plans to modify the bases and SRs to be consistent by using either "unit" or "plant."

3. You made several changes to Bases Sections 3.1.C and 4.13 that go beyond TSTF-449. Please confirm that all of the proposed changes are consistent with your current Nuclear Regulatory Commission (NRC) approved design and licensing basis. If they are not consistent, please provide the technical justification or discuss your plans to remove them. In addition, discuss why the statement concerning General Design Criterion 30 and Regulatory Guide 1.45 was not included in the proposed bases for TS Section 3.1.C.

4. In several TSs (e.g., TS Section 3.1.C, Applicability Section of TS Bases Sections 3.1.C, 3.1.H, 3.1.H.2.b, Bases Sections 3.1.H.2.a and b, 4.19.B), terminology such as "whenever REACTOR OPERATION exceeds COLD SHUTDOWN conditions" is used.

This terminology is not clear since both refueling shutdown and intermediate shutdown conditions "exceed" cold shutdown conditions (depending on your perspective). Please discuss your plans to more clearly specify the requirement.

For example, in proposed TS Section 3.1.C: "The following specifications are applicable to RCS [reactor coolant system] operational LEAKAGE during the following REACTOR OPERATION conditions: INTERMEDIATE SHUTDOWN, HOT SHUTDOWN, REACTOR CRITICAL, and POWER OPERATION." Another example would be: "The following specifications are applicable to RCS operational LEAKAGE whenever Tavg (average temperature) exceeds 200°F (200 degrees Fahrenheit)."

In proposed TS Section 3.1.H.2.b, it may be acceptable to replace "exceeding" with "exiting" consistent with the wording in proposed TS Section 6.6.A.3.

5. Please provide justification for removing "...to be met until the next refueling outage..."

from proposed Bases Sections 3.1.H.2.a and b or alternatively discuss your plans to Enclosure

modify these bases sections to state "...to be met until the next refueling outage or SG tube inspection."

6. In the second paragraph of proposed SR 4.13.A, there appears to be a typographical error, "met" should be "performed." Please discuss your plans to correct this typographical error.

7. You deleted the existing Bases for proposed TS Section 3.1.C which describes various leak detection instruments. Please discuss whether this information is captured elsewhere in your TSs. The NRC staff notes that in the Bases for TS Section 4.13 you did not propose to incorporate the following sentence from the standard TSs: "These leakage detections systems are specified in LCO (Limiting Condition for Operation) 3.4.15, "RCS Leakage Detection Instrumentation." If the information concerning the leakage detection instruments is not captured elsewhere, please discuss your plans to leave it in TS Section 3.1.C and to incorporate a sentence into the Bases for TS Section 4.13 indicating that the leakage detection instruments are specified in the Bases of TS Section 3.1.

8. In proposed TS Section 3.1.H, it would appear that TS Section 3.1.H.2 would permit you to elect not to plug a tube provided the conditions in TS Section 3.1.H.2.a and TS Section 3.1.H.2.b were met. This is not consistent with the Technical Specification Task Force (TSTF) -449. In TSTF-449, the required actions are intended to apply only in the event that a tube that should have been plugged was inadvertently not plugged rather than electing not to plug a tube. Please discuss your plans to clarify your TSs in this regard. For example, terminology such as, "If the requirements of 3.1.H.1 are not met for one or more SG tubes, then perform the following:"

9. In proposed TS Section 4.13.A, you proposed relaxing the surveillance frequency for verifying RCS operational leakage from daily to once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Please discuss your plans to modify this requirement to be consistent with your existing TSs since this change is not consistent with TSTF-449.

10. In several sections of your proposed TSs, there are "Applicability" and "Objective" sections. Please discuss why these sections are not included in every proposed TS section.

Enclosure

Surry Power Station, Units 1 & 2 cc:

Ms. Lillian M. Cuoco, Esq. Office of the Attorney General Senior Counsel Commonwealth of Virginia Dominion Resources Services, Inc. 900 East Main Street Building 475, 5th Floor Richmond, Virginia 23219 Rope Ferry Road Waterford, Connecticut 06385 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Mr. Donald E. Jernigan Dominion Resources Services, Inc.

Site Vice President Innsbrook Technical Center Surry Power Station 5000 Dominion Blvd.

Virginia Electric and Power Company Glen Allen, Virginia 23060-6711 5570 Hog Island Road Surry, Virginia 23883-0315 Senior Resident Inspector Surry Power Station U. S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 Dr. Robert B. Stroube, MD, MPH State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218