ML14038A213
| ML14038A213 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/07/2014 |
| From: | V Sreenivas Plant Licensing Branch II |
| To: | Heacock D Dominion Energy Co |
| References | |
| Download: ML14038A213 (3) | |
Text
1 NRR-PMDAPEm Resource From:
Sreenivas, V Sent:
Friday, February 07, 2014 9:49 AM To:
'david.heacock@dom.com' Cc:
'david.sommers@dom.com'; Pascarelli, Robert; Barillas, Martha; 'Gary D Miller'; Tom Shaub
Subject:
RE: SURRY POWER STATION-UNIT2: RAI: ALTERNATIVE SPT-002 RE: ALTERNATIVE TESTING REQUIREMENTS FOR SMALL DIAMETER REACTOR COOLANT SYSTEM PRESSURE BOUNDARY CONNECTIONS REQUEST FOR ADDITIONAL INFORMATION REQUEST FOR ALTERNATIVE SPT-002 REGARDING ALTERNATIVE TESTING REQUIREMENTS FOR SMALL DIAMETER REACTOR COOLANT SYSTEM PRESSURE BOUNDARY CONNECTIONS VIRGINIA ELECTRIC AND POWER COMPANY - DOMINION SURRY POWER STATION, UNIT 2 DOCKET NUMBER 50-281 By letter dated December 9, 2013 (Agencywide Documents Access and Management Systems (ADAMS)
Accession No. ML13350A109), Virginia Electric and Power Company - Dominion (the licensee) submitted for the U.S. Nuclear Regulatory Commission (NRC) approval request for alternative (RFA) SPT-002. The licensee proposed an alternative to a certain requirement of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI. RFA SPT-002 relates to the inservice inspection (ISI) requirement specified in IWB-5222(b) for system leakage testing conducted at or near the end of the inspection interval. The licensee submitted the request for the Surry Power Station (Surry), Unit 2.
The NRC staff requests the following additional information.
- 1. The licensee submitted RFA SPT-002 pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i). In accordance with 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes a proposed alternative to the ASME Code requirement only if the alternative is equivalent in quality to the ASME Code requirement. The staff finds that the proposed alternative boundary for the system leakage test would not achieve the equivalent of quality of the ASME Code requirement specified in IWB-5222(b).
The NRC staff finds that submitting the proposed alternative with a hardship justification pursuant to 10 CFR 50.55a(a)(3)(ii) would be appropriate and acceptable. Please revise RFA SPT-002 accordingly or justify why the proposed alternative satisfies 10 CFR 50.55a(a)(3)(i).
- 2.Section III of Attachment 2 of the request states, in part. that This code case [N-798] allows the use of IWB-5222(a) for defining the pressure retaining boundary as an acceptable alternative to the extended pressure test boundaries of IWB-5222(b)
Item (1),Section IV, Attachment 2 of the request states, in part, that The RCS vent, drain, instrumentation, and sample connections will be visually examined for leakage and any evidence of past leakage, with the isolation valves in the normally closed position each refueling outage during the ASME Section Xl Class 1 System Leakage Test (IWB-5220)
The NRC staff notes that IWB-5220 contains two subparagraphs, IWB-5221 and IWB-5222. It is not clear to the NRC staff which subparagraph(s) the proposed alternative will be following. Please clarify whether the proposed alternative is to use the boundary specified in ASME Code Case N-798, or IWB-5222(a), in lieu of the requirement of IWB-5222(b).
- 3. Discuss in detail the hardships or unusual difficulties associated with compliance to IWB-5222(b) requirement when performing pressure tests. (Examples of hardship or unusual difficulty may include having to enter multiple technical specification (TS) limiting conditions for operations (LCO), radiation
2 dose and as low as is reasonably achievable (ALARA) concerns, creating excessive plant personnel hazards, causing reactor shut down, and defeat of the double isolation barrier.) The Sequoyah request for alternative 11-SPT-1 (ADAMS Accession No. ML13178A280) may provide additional examples.
- 4. Clarify whether the proposed alternative is for the piping segments identified in both tables on page 3 of of the request.
- 5. The NRC staff notes that the combined piping segments identified in both tables on page 3 of of the request contain exactly 15 segments. Clarify why Section I of Attachment 2 of the request states, approximately 20 connections.
- 6. Provide the name of system(s) for each piping segment listed in both tables on page 3 of Attachment 2 of the request.
- 7. Provide materials of construction for each piping segment listed in both tables on page 3 of Attachment 2 of the request.
- 8. Confirm that the code of record for the fourth 10-year ISI interval at Surry, Unit 2, is the 1998 Edition through 2000 Addenda of the ASME Code.
- 9. For justifications that the structural integrity and leak tightness of the piping and associated components (listed in both tables on page 3 of Attachment 2 of the request) will be reasonably ensured without required extension in pressure retaining boundary during system leakage test, discuss operating experience (i.e., plant specific, fleet, and industry) regarding potential degradation of the subject piping and components due to known degradation mechanisms (e.g., fatigue and stress corrosion cracking) that would lead to leakage.
Please submit the response to these RAIs by March 10, 2014. If you have any questions please contact me at your earliest.
V. Sreenivas, PH.D., C.P.M.,
Project Manager, Rm.#O8F6, LPL2-1 North Anna and Surry Power Stations, Units 1 and 2 Division of Operating Reactor Licensing-NRR (301) 415-2597, v.sreenivas@nrc.gov
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Hearing Identifier:
NRR_PMDA Email Number:
1073 Mail Envelope Properties (V.Sreenivas@nrc.gov20140207094800)
Subject:
RE: SURRY POWER STATION-UNIT2: RAI: ALTERNATIVE SPT-002 RE:
ALTERNATIVE TESTING REQUIREMENTS FOR SMALL DIAMETER REACTOR COOLANT SYSTEM PRESSURE BOUNDARY CONNECTIONS Sent Date:
2/7/2014 9:48:47 AM Received Date:
2/7/2014 9:48:00 AM From:
Sreenivas, V Created By:
V.Sreenivas@nrc.gov Recipients:
"'david.sommers@dom.com'" <david.sommers@dom.com>
Tracking Status: None "Pascarelli, Robert" <Robert.Pascarelli@nrc.gov>
Tracking Status: None "Barillas, Martha" <Martha.Barillas@nrc.gov>
Tracking Status: None
"'Gary D Miller'" <gary.d.miller@dom.com>
Tracking Status: None "Tom Shaub" <tom.shaub@dom.com>
Tracking Status: None
"'david.heacock@dom.com'" <david.heacock@dom.com>
Tracking Status: None Post Office:
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