ML093340553

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Correction Letter for License Amendment Nos. 266 and 265, Regarding Removal of Main Control Room Bottled Air System
ML093340553
Person / Time
Site: Surry  Dominion icon.png
Issue date: 12/03/2009
From: Cotton K
Plant Licensing Branch II
To: Heacock D
Virginia Electric & Power Co (VEPCO)
Cotton K, NRR/DLPM, 301-415-1438
Shared Package
ML093340544 List:
References
TAC MD9891, TAC MD9918
Download: ML093340553 (8)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 3, 2009 Mr. David A. Heacock 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 - CORRECTION LETTER FOR LICENSE AMENDMENT NOS. 266 AND 265, REGARDING REMOVAL OF MAIN CONTROL ROOM BOTTLED AIR SYSTEM (TAC NOS. MD9891 AND MD9918)

Dear Mr. Heacock:

By letter dated October 29,2009, the U.S. Nuclear Regulatory Commission (NRC) staff issued Amendment No. 266 to Renewed Facility Operating License No. DPR-32 and Amendment No. 265 to Renewed Facility Operating License No. DPR-37 for Surry Power Station, Unit Nos. 1 and 2, respectively. The amendments change the Technical Specifications (TSs) in response to your application dated October 9, 2008.

Subsequently, Mr. Gary Miller of your staff informed the NRC staff in an e-mail dated November 2,2009 (Agencywide Documents Access Management System (ADAMS) Accession No. ML093340520), of two missing Technical Specification (TS) pages, TS 4.1-9c and TS 6.4-14 and some related Bases pages TS 3.21-2, TS 3.21-3 and TS 4.1-5. Please replace the errata sheet and add the enclosed TS pages along with the related supporting Bases pages.

The correction does not change the approval conveyed by the amendments, or the conclusion reached by the associated safety evaluation. We regret any inconvenience this error may have caused you.

If you have any additional questions regarding this matter, I may be reached at 301-415-1438.

Sincerely, fu1Y'1(J;f!;;5 Karen Cotton, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281

Enclosures:

Errata Sheet and Technical Specification Pages cc w/encls: Distribution via Listserv

ATTACHMENT TO LICENSE AMENDMENT NO. 266 RENEWED FACILITY OPERATING LICENSE NO. DPR-32 DOCKET NO. 50-280 AND TO LICENSE AMENDMENT NO. 265 RENEWED FACILITY OPERATING LICENSE NO. DPR-37 DOCKET NO. 50-281 Replace the following pages of the Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License License No. DPR-32, page 3 License No. DPR-32, page 3 License No. DPR-37, page 3 License No. DPR-37, pqge 3 TSs TSs ii ii 3.7-2 3.7-2 3.7-3 3.7-3 3.7-9 3.7-9 3.7-9a 3.7-9b 3.7-9c 3.10-4 3.10-4 3.10-5 3.10-5 3.10-8 3.10-8 3.10-9 3.10-9 3.19-1 3.19-2 3.19-3 3.19-4 3.21-2 3.21-2 3.21-3 3.21-3 4.1-5 4.1-5 4.1-9c 4.1-9c 6.4-14 6.4-14 Corrected by letter dated December 3, 2009

c TS 3.21-2 BASES BACKGROUND - The MCRJESGR Emergency Ventilation System (EVS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The MCRJESGR EVS consists of four full capacity trains that supply filtered air to the MCRIESGR envelope and a MCR/ESGR envelope boundary that limits the inleakage of unfiltered air. Each MCRJESGR EVS train consists of a prefilter, a high efficiency particulate air (HEPA) :filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves, dampers, doors, barriers, and instrumentation also fonn part of the system. One EVS train is capable of performing the safety function of providing outside filtered air for pressurization. Two independently powered EVS trains are required for independence and redundancy.

The MCRlESGR envelope is the area within the confines of the MCRlESGR envelope boundary that contains the spaces that control room occupants inhabit to control the unit during nonnal and accident conditions. This area encompasses the common Main Control Room and the Emergency Switchgear Rooms, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The MCRlESGR envelope is protected during normal operation, natural events, and accident conditions. The MCR/ESGR envelope boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the MCRlESGR envelope. The OPERABll..,ITY of the MCRIESGR envelope boundary must be maintained to ensure that the inleakage of unfiltered air into the MCR/ESGR envelope will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to MCRlESGR envelope occupants. The MCRlESGR envelope and its boundary are defined in the MCRJESGR Envelope Habitability Program (TS 6.4.R).

Upon receipt of the actuating signal(s), nonnal air supply to and exhaust from the MCRlESGR envelope is isolated. Two dampers in series in both the MCRlESGR envelope supply and exhaust ducts close to isolate the MCRlESGR envelope. Approximately 60 minutes after the isolation of the MCRJESGR envelope, the MCRJESGR EVS is manually actuated. Each MCRJESGR EVS train provides filtered air from the Thrbine Building to the MCRlESGR envelope through HEPA filters and charcoal adsorbers. Prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers.

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Amendment Nos. 266, 265 Corrected by letter dated December 3, 2009

TS 3.21-3 Pressurization of the MCRJESGR envelope, although not required by the accident analyses, limits infIltration of unfiltered air from the surrounding areas adjacent to the MCRJESGR envelope.

A single train of the MCRlESGR EVS will pressurize the MCRlESGR envelope to about 0.05 inches water gauge relative to external areas adjacent to the MCRJESGR envelope boundary.

The MCRJESGR EVS operation in maintaining the MCRJESGR envelope habitable is discussed in the UFSAR, Section 9.13 (Ref. 3).

Redundant MCRlESGR EVS supply trains provide pressurization and filtration should one train fail to start or should an excessive pressure drop develop across the operating filter train. Isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The MCRlESGR EVS is designed in accordance with Seismic Category I requirements.

The MCRIESGR EVS is designed to maintain a habitable environment in the MCRIESGR envelope for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem total effective dose equivalent (TEDE).

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APPLICABLE SAFETY ANALYSES - The MCRlESGR EVS components are arranged in redundant, safety related ventilation trains. The MCR/ESGR EVS provides airborne radiological protection for the MCRJESGR envelope occupants, as demonstrated by the MCRJESGR envelope occupant dose analyses for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 14 (Ref. 4).

The MCRlESGR EVS provides protection from smoke and hazardous chemicals to the MCRlESGR envelope occupants. An evaluation of hazardous chemical releases demonstrates that the toxicity limits for chemicals are not exceeded in the MCRJESGR envelope following a hazardous chemical release (Refs. 1 and 5) or that ample time is available for MCRlESGR envelope occupants to isolate the MCRlESGR envelope. The evaluation of a smoke challenge demonstrates that it will not result in the inability of the MCRJESGR envelope occupants to control the reactor either from the MCR or from the remote shutdown panel (Ref. 2).

The worst case single active failure of a component of the MCRJESGR EVS, assuming a loss of offsite power, does not impair the ability of the system to perfonn its design function.

The MCRJESGR EVS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LIMITING CONDITIONS FOR OPERATION (LCO) - Two independent and redundant MCRJESGR EVS trains are required to be OPERABLE to ensure that at least one is available to pressurize and to provide filtered air to the MCRlESGR envelope assuming a single active failure disables one of the two required trains. Due to electrical power considerations, one train must be from the other unit. Total system failure, such as from a loss of both ventilation trains or from an inoperable MCRlESGR envelope boundary, could result in exceeding a dose of 5 rem TEDE to the MCRlESGR envelope occupants in the event of a large radioactive release.

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Amendment Nos. 266, 265 Corrected by letter dated December 3, 2009

TS 4.1-5 The refueling water storage tank is sampled weekly for CI-and/or F contaminations. Weekly sampling is adequate to detect any inleakage of contaminated water.

Main Control RoomlEmergency Switchgear Room (MCRIESGR) Envelope Isolation Actuation Instrumentation The MCRlESGR Envelope Isolation Actuation function provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity. A functional check of the Manual Actuation function is performed every 18 months. The test frequency is based on the known reliability of the function and the redundancy available and has been shown to be acceptable through operating experience. The Surveillance Requirement will ensure that the two trains of the MCRlESGR envelope isolation dampers close upon manual actuation of the MCRlESGR Envelope Isolation Actuation Instrumentation and that the supply and exhaust fans in the normal ventilation system for the MCRIESGR envelope shut down, as well as adjacent area ventilation fans.

Automatic actuation of the MCR/ESGR Envelope Isolation Actuation Instrumentation is confirmed as part of the Logic Channel Testing for the Safety Injection system.

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Pressurizer PORV, PORV Block Valve, and PORV Backup Air Supply The safety-related, seismic PORV backup air supply is relied upon for two functions - mitigation of a design basis steam generator tube rupture accident and low temperature overpressure protection (LTOP) of the reactor vessel during startup and shutdown. The surveillance criteria are based upon the more limiting requirements for the backup air supply (Le. more PORV cycles potentially required to perform the mitigation function), which are associated with the LTOP function.

The PORV backup air supply system is provided with a calibrated alarm for low air pressure. The alarm is located in the control room. Failures such as regulator drift and air leaks which result in low pressure can be easily recognized by alarm or annunciator action. A periodic quarterly verification of air pressure against the surveillance limit supplements this type of built-in surveillance. Based on experience in operation, the minimum checking frequencies set forth are deemed adequate.

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Amendment Nos. 266, 265 Corrected by letter dated December 3, 2009

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TABLE 4.1-2A (CONTINUED)

MINIMUM FREQUENCY FOR EQUIPMENT 1ESTS FSAR SECTION DESCRIPTION TEST FREQUENCY REFERENCE 14a. Service Water System Valves in Line Functional Once per 18 months 9.9 Supplying Recirculation Spray Heat Exchangers

b. Service Water System Valves Isolating Functional Once per 18 months 9.9 Flow to Non-essential loads on Intake Canal Low Level Isolation
15. MCRJESGR Envelope Isolation Functional Once per 18 months 9.13 Actuation Instrumentation - Manual
16. Reactor Vessel Overpressure Functional & Setpoint Prior to decreasing RCS 4.3

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TS 6.4-14 R. Main Control RoomlEmergency Switchgear Room (MCRJESGR) Envelope Habitability Program A Main Control RoomlEmergency Switchgear Room (MCRJESGR) Envelope Habitability Program shall be established and implemented to ensure that MCRlESGR envelope habitability is maintained such that, with an OPERABLE MCRlESGR Emergency Ventilation System (EVS), MCRlESGR envelope occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the MCRlESGR envelope under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

1. The definition of the MCRJESGR envelope and the MCRJESGR envelope boundary.
2. Requirements for maintaining the MCRlESGR envelope boundary in its design condition including configuration control and preventive maintenance.
3. Requirements for (a) determining the unfiltered air inleakage past the MCRlESGR envelope boundary into the MCRJESGR envelope in accordance with the testing

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methods and at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (b) assessing MCRJESGR envelope habitability at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, Revision O.

The following is an exception to Sections C.l and C.2 of Regulatory Guide 1.197, Revision 0:

  • 2.C.l Licensing Bases - Vulnerability assessments for radiological, hazardous chemical and smoke, and emergency ventilation system testing were completed as documented in the UFSAR. The exceptions to the Regulatory Guides (RGs) referenced in RG 1.196 (i.e., RG 1.52, RG 1.78 and RG 1.183), which were considered in completing the vulnerability assessments, are documented in the UFSARlcurrent licensing basis. Compliance with these RGs is consistent with the current licensing basis as described in the UFSAR.

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Amendment Nos. 266, 265 Corrected by letter dated December 3, 2009

ML093340553 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRRlLPL2-1/BC NAME KCotton MOBrien GKulesa (VSreenivas for)

DATE 12/2/09 12/2/09 12/3/09