ML091040147

Proposed License Amendment Request Correction to Technical Specification Table 3.7-1 Operator Action 3.b

ML091040147
Person / Time
Site:	Surry
Issue date:	04/13/2009
From:	Hartz L Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
09-208
Download: ML091040147 (13)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 13. 2009 10CFR50.90 U. S. Nuclear Regulatory Commission Serial No.09-208 ATTN: Document Control Desk SPS-L1C/CGL RO Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST CORRECTION TO TECHNICAL SPECIFICATION TABLE 3.7-1 OPERATOR ACTION 3.b Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) requests amendments, in the form of changes to the Technical Specifications (TS) to Facility Operating License Numbers DPR-32 and DPR-37 for Surry Power Station Units 1 and 2, respectively. The proposed change revises TS Table 3.7-1 Operator Action 3.b and provides direction if the less-than-required-minimum-operable-channels-condition for the nuclear flux intermediate range occurs between 7% and 11 % of rated power.

This revision is a correction of the information transmitted to the NRC by the September 19, 2007 letter (Serial No. 07-0470), which requested review of revised setting limits and overtemperature LlT/overpower LlT time constants. A discussion of the proposed change is provided in Attachment 1. The marked-up and typed proposed TS pages are provided in Attachments 2 and 3, respectively.

We have evaluated the proposed amendment and have determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. The basis for this determination is included in Attachment 1. We have also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change. The proposed TS change has been reviewed and approved by the Facility Safety Review Committee. NRC approval of the proposed license amendment is requested by April 15, 2010 with a 30-day implementation period.

Serial No.09-208 Docket Nos. 50-280/281 Page 2 of 3 If you have any questions or require additional information, please contact Mr. Gary D.

Miller at (804) 273-2771.

Sincerely,

"-"'1) // c7f..

L. N. Hartz Vice President - Nuclear Support Services Attachments

1. Discussion of Change

2. Proposed Technical Specifications Page (Mark-Up)

3. Proposed Technical Specifications Page (Typed)

Commitments made in this letter: None COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Support Services, of Virginia Electric and Power Company. She has affirmed before me that she 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 her knowledge and belief.

Acknowledged before me this \ 3+-'h day of ben' I ,2009.

My Commission Expires:

c**

L 11.1.""'"

11'"

~~

Otaryp~ .

Serial No.09-208 Docket Nos. 50-280/281 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 NRC Senior Resident Inspector Surry Power Station State Health Commissioner Virginia Department of Health James Madison Building - i h Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Ms. D. N. Wright NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8H4A Rockville, Maryland 20852 Mr. J. F. Stang, Jr.

NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8G9A Rockville, Maryland 20852

Serial No.09-208 Docket Nos. 50-280/281 ATTACHMENT 1 DISCUSSION OF CHANGE Virginia Electric and Power Company (Dominion)

Surry Power Station Units 1 and 2

Serial No.09-208 Docket Nos. 50-280/281 Attachment 1 DISCUSSION OF CHANGE

1.0 INTRODUCTION

Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) requests a revision to the Technical Specifications (TS) for Surry Power Station Units 1 and 2. The proposed change revises TS Table 3.7-1 Operator Action 3.b and provides direction if the less-than-required-minimum-operable-channels-condition for the nuclear flux intermediate range occurs between 7% and 11 % of rated power. This revision is a correction of the information transmitted to the NRC by the September 19, 2007 letter (Serial No. 07-0470), which requested review of revised setting limits and overtemperature I1T/overpower I1T time constants.

The proposed change has been reviewed, and it has been determined that the change has no adverse safety impact and that no significant hazards consideration exists as defined in 10 CFR 50.92. In addition, it has been determined that the change qualifies for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9); therefore, no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

2.0 BACKGROUND

On September 19, 2007, Dominion transmitted a letter (Serial No. 07-0470) requesting NRC review and approval of a TS change revising setting limits and overtemperature I1T/overpower I1T time constants. The methodology for determining these revised setting limits and time constants was in agreement with Methods 1 and 2 in ISA-RP67.04, Part II. The TS change request in our September 19,2007 letter was subsequently approved by the NRC by TS Amendments 261/261 on September 17,2008.

The revision in our September 19, 2007 letter of interest is the following change:

Table 3.7-1, ACTION 3.b prior to implementation of TS Amendments 261/261 stated:

b. Above the P-6 (Block of Source Range Reactor Trip) setpoint, but below 10% of RATED POWER, decrease power below P-6 or, increase THERMAL POWER above 10% of RATED POWER within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Table 3.7-1, ACTION 3.b after implementation of TS Amendments 261/261 states:

b. Above the P-6 (Block of Source Range Reactor Trip) setpoint, but below 7% of RATED POWER, decrease power below P-6 or, increase THERMAL POWER above 11 % of RATED POWER within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Page 1 of 5

Serial No.09-208 Docket Nos. 50-280/281 Attachment 1 TS Amendments 261/261 were implemented on November 5, 2008. Subsequently, during simulator training, a question was raised requesting clarification regarding application of TS Table 3.7-1 Operator Action 3.b, and a Condition Report (CR) was submitted documenting the question. During initial investigation of the CR question, it was recognized that Operator Action 3.b as written does not specify actions to be taken if the less-than-required-minimum-operable-channels-condition for the nuclear flux intermediate range occurs between 7% and 11 % of rated power. Furthermore, it was concluded that the actions directed by Operator Action 3.b are inadequate.

NRC Administrative Letter (AL) 98-10 addresses improper or inadequate TS requirements and states that imposition of administrative controls is an acceptable short-term corrective action in response to an improper or inadequate TS. Consistent with this guidance in AL 98-10 to impose administrative controls, revisions were made to the Units 1 and 2 Abnormal Procedures for Nuclear Instrumentation Malfunction providing direction for nuclear flux intermediate range channel inoperability for rated power levels between 7% and 11%. In addition, AL 98-10 indicates that a TS change request with appropriate justification shall be submitted in a timely manner. The purpose of this TS change request is to correct TS Table 3.7-1 Operator Action 3.b.

3.0 PROPOSED CHANGE

The following specific revision is proposed to correct TS Table 3.7-1 Operator Action 3.b.

Table 3.7-1, ACTION 3.b currently states:

b. Above the P-6 (Block of Source Range Reactor Trip) setpoint, but below 7% of RATED POWER, decrease power below P-6 or, increase THERMAL POWER above 11 % of RATED POWER within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The proposed revision to Table 3.7-1, ACTION 3.b is as follows:

b. Above the P-6 (Block of Source Range Reactor Trip) setpoint, but below 11 % of RATED POWER, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, decrease power below P-6 or increase TH ERMAL POWER above 11 % of RATED POWER.

4.0 TECHNICAL BASIS OF PROPOSED CHANGE As indicated in the proposed change discussion above, the appropriate action for nuclear flux intermediate range channel inoperability at rated power levels between 7%

and 11 % is to decrease power below P-6 or increase thermal power above 11 % of rated Page 2 of 5

Serial No.09-208 Docket Nos. 50-280/281 Attachment 1 power, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 7% of rated power level was inappropriately reflected in Operator Action 3.b in the September 19,2007 letter (Serial No. 07-0470).

5.0 SIGNIFICANT HAZARDS CONSIDERATION Virginia Electric and Power Company (Dominion) is proposing a revIsion to the Technical Specifications (TS) for Surry Power Station Units 1 and 2. The proposed change revises TS Table 3.7-1 Operator Action 3.b and provides direction if the less-than-required-minimum-operable-channels-condition for the nuclear flux intermediate range occurs between 7% and 11 % of rated power. Upon discovery that Operator Action 3.b revised by TS Amendments 261/261 did not include direction for inoperability in this power range, administrative controls were put in place to provide the lacking direction in accordance with NRC Administrative Letter 98-10.

Dominion has reviewed the requirements of 10 CFR 50.92 as they relate to the proposed changes to the Surry Power Station Units 1 and 2 TS and has determined that a significant hazards consideration does not exist. The basis for this determination is provided as follows:

1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

No. The proposed change revises TS Table 3.7-1 Operator Action 3.b and provides direction if the less-than-required-minimum-operable-channels-condition for the nuclear flux intermediate range occurs between 7% and 11 % of rated power.

Required action between 7% and 11 % of rated power is currently not addressed in the Operator Action 3.b. The proposed TS change does not involve a physical change to any structures, systems, or components (SSCs) at Surry Power Station; nor does it change any of the previously evaluated accidents in the Updated Final Safety Analysis Report (UFSAR). Thus, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed license amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

No. The proposed change revises TS Table 3.7-1 Operator Action 3.b, and provides required action between 7% and 11 % of rated power, which is currently not addressed in the Operator Action 3.b. The proposed change does not involve a physical change to any SSCs, and there is no impact on their design function. The proposed change does not affect initiators of analyzed events. Therefore, the proposed change does not introduce any new failures that could create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 3 of 5

Serial No.09-208 Docket Nos. 50-280/281 Attachment 1

3. Does the proposed amendment involve a significant reduction in a margin of safety?

No. The proposed change provides required action for inoperability of nuclear flux intermediate range instrumentation between 7% and 11 % of rated power in TS Table 3.7-1 Operator Action 3.b. Margin of safety is established through the design of plant SSCs, the parameters within which the plant is operated, and the establishment of the setpoints for the actuation of equipment relied upon to respond to an event. The proposed change does not impact the condition or performance of SSCs relied upon for accident mitigation or any safety analysis assumptions.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

6.0 ENVIRONMENTAL ASSESSMENT This amendment request meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) as follows:

(i) The amendment involves no significant hazards consideration.

As described above, the proposed Technical Specification change does not involve a significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed TS change does not involve the installation of any new equipment or a physical change to any structures, systems, or components (SSCs) at Surry Power Station. Therefore, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed TS change does not involve plant physical changes and does not require any changes to current plant operation. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure.

Based on the above assessment, Dominion concludes that the proposed change meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.22 relative to requiring a specific environmental assessment or impact statement by the Commission.

Page 4 of 5

Serial No.09-208 Docket Nos. 50-280/281 Attachment 1

7.0 CONCLUSION

The proposed change revises TS Table 3.7-1 Operator Action 3.b and provides direction if the less-than-required-minimum-operable-channels-condition for the nuclear flux intermediate range occurs between 7% and 11 % of rated power.

The proposed TS change does not involve the installation of any new equipment or a physical change to any SSCs at Surry Power Station and does not impact any SSC design function. In addition, the proposed change does not affect initiators of analyzed events, does not impact the condition or performance of SSCs relied upon for accident mitigation, and does not impact any safety analysis assumptions.

The Facility Safety Review Committee (FSRC) has reviewed the proposed change, and it has been concluded that this change does not have an adverse impact on safety, does not involve a significant hazards consideration, and will not endanger the health and safety of the public.

8.0 REFERENCES

8.1 Letter Serial No. 07-0470, dated September 19, 2007, to U. S. Nuclear Regulatory Commission, "Virginia Electric and Power Company - Surry Power Station Units 1 and 2 - Proposed Technical Specifications Change - Revised Setting Limits and Overtemperature fj. T/Overpower fj. T Time Constants" 8.2 Letter from Siva P. Lingam, Office of Nuclear Reactor Regulation, dated September 17, 2008, "Surry Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding the Revision to Various Setting Limits and the Overtemperature ~T/Overpower ~T Time Constants (TAC Nos. MD6812 and MD6813)"

Page 5 of 5

Serial No.09-208 Docket Nos. 50-280 and 281 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARK-UP)

Virginia Electric and Power Company (Dominion)

Surry Power Station Units 1 and 2

TS 3.7-14 99 1798 .

TABLE 3.7-1 (Continued)

4. The QUADRANT POWER TILT shall be determined to be within the limit when above 75 percent of RATED POWER with one Power Range Channel inoperable by using the moveable incore detectors to confirm that the normalized symmetric power distribution, obtained from 2 sets of 4 symmetric thimble locations or a full-core flux map, is consistent with the indicated QUADRANT POWER TILT at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

With the number of OPERABLE channels one less than required by the Minimum OPERABLE Channels requirement, be in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ACTION 3. With the number of OPERABLE channels one less than required by the Minimum OPERABLE Channels requirement and with the THERMAL POWER Jlevel:

a. Below the P-6 (Block of Source Range Reactor Trip) setpoint, restore the inoperable channel to OPERABLE status prior to increilsing THERMAL POWER above the P-6 Setpoint.

b. AbOV~-6 (Block of Source Range Reactor Trip) setpoint, but 1'70 below of RATED POWER,flecrease power below P-6 01)< t

~;e TIIIlRMAL POWER above 11% of RAlED POWER. l within 24 ho~

c. Abovc~ 11% of RATED POWER, POWER OPERATION may ~

continue.

Amendment Nos. ~l aftEl261-

Serial No.09-208 Docket Nos. 50-280 and 281 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS PAGE (TYPED)

Virginia Electric and Power Company (Dominion)

Surry Power Station Units 1 and 2

TS 3.7-14 TBD TABLE 3.7-1 (Continued)

4. The QUADRANT POWER TILT shall be determined to be within the limit when above 75 percent of RATED POWER with one Power Range Channel inoperable by using the moveable incore detectors to confirm that the normalized symmetric power distribution, obtained from 2 sets of 4 symmetric thimble locations or a full-core flux map, is consistent with the indicated QUADRANT POWER TILT at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

With the number of OPERABLE channels one less than required by the Minimum OPERABLE Channels requirement, be in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ACTION 3. With the number of OPERABLE channels one less than required by the Minimum OPERABLE Channels requirement and with the THERMAL POWER level:

a. Below the P-6 (Block of Source Range Reactor Trip) setpoint, restore the inoperable channel to OPERABLE status prior to increasing THERMAL POWER above the P-6 Setpoint.

b. Above the P-6 (Block of Source Range Reactor Trip) setpoint, but below 11 % of RATED POWER, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, decrease power below P-6 or increase THERMAL POWER above 11 % of RATED POWER.

c. Above 11 % of RATED POWER, POWER OPERATION may continue.

Amendment Nos.