ML14091A262

Response to NRC Request for Additional Information Proposed License Amendment Request Permanent Fifteen-Year Type a Test Interval

ML14091A262
Person / Time
Site:	Surry
Issue date:	03/25/2014
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-435C, SPS-LIC/CGL
Download: ML14091A262 (6)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 25, 2014 10 CFR 50.90 U. S. Nuclear Regulatory Commission Serial No.: 13-435C Attention: Document Control Desk SPS-LIC/CGL: RD Washington, DC 20555-0001 Docket Nos.: 50-280 50-281 License Nos.: DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION PROPOSED LICENSE AMENDMENT REQUEST PERMANENT FIFTEEN-YEAR TYPE A TEST INTERVAL By a letter dated August 12, 2013 (Serial No.13-435), Virginia Electric and Power Company (Dominion) requested license amendments in the form of changes to the Technical Specifications for facility Operating License Numbers DPR-32 and DPR-37 for Surry Power Station (Surry) Units 1 and 2, respectively. The proposed amendments revise the Surry Units 1 and 2 Technical Specification (TS) 4.4.B, "Containment Leakage Rate Testing Requirements," by replacing the reference to Regulatory Guide (RG) 1.163 with a reference to Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, as the implementation document used to develop the Surry performance-based leakage testing program in accordance with Option B of 10 CFR 50, Appendix J. Revision 3-A of NEI 94-01 describes an approach for implementing the optional performance-based requirements of Option B, including provisions for extending the Type A primary containment integrated leak rate test (ILRT) intervals to fifteen years and the Type C local leak rate test intervals to 75 months, and incorporates the regulatory positions stated in RG 1.163.

On February 28, 2014, the NRC requested additional information regarding the proposed license amendment request. The response to the NRC's request for additional information is provided in the attachment.

The information provided in this letter does not affect the conclusion of the significant hazards consideration discussed in the August 12, 2013 letter (Serial No.13-435).

Serial No. 13-435C Docket Nos. 50-280/281 Page 2 of 3 Should you have any questions or require additional information, please contact Mr. Gary Miller at (804) 273-2771.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering Attachment - Response to NRC Request for Additional Information Dated February 28, 2014 Commitments contained in this letter: None.

VICKI L. HULL Notary Public Commonwealth of Virginia COMMONWEALTH OF VIRGINIA )I 140542 My Commission Expires May 31. 2014

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COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mr. Mark D. Sartain, who is Vice President - Nuclear Engineering of Virginia Electric and Power Company. He has affirmed before me that he 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 his knowledge and belief.

Acknowledged before me this

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Serial No. 13-435C Docket Nos. 50-280/281 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 State Health Commissioner Virginia Department of Health James Madison Building - 7 th floor 109 Governor Street Suite 730 Richmond, VA 23219 Ms. M. C. Barillas NRC Project Manager Surry U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station

Serial No. 13-435C Docket Nos. 50-280/281 Attachment Response to NRC Request for Additional Information Dated February 28, 2014 Virginia Electric and Power Company (Dominion)

Surry Power Station Units I and 2

Serial No. 13-435C Docket Nos. 50-280/281 Attachment Page 1 of 2 Response to Request for Additional Information Regarding the Proposed License Amendment Request Extension of Type A and C Test Intervals By a letter dated August 12, 2013 (Serial No.13-435 / Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML13232A042), Dominion requested license amendments to revise the Surry containment leakage rate testing program, including provisions for extending Type A primary containment integrated leak rate test (ILRT) intervals to 15 years and Type C test intervals to 75 months.

On February 28, 2014, the NRC staff requested additional information to complete its review. The NRC questions and Dominion responses are provided below.

1. What is the peak containment pressure (Pa) for Type A testing performed in Surry Units I & 2?

Dominion Response: The current LOCA analysis peak calculated pressure (Pa) is 43.95 psig. The containment LOCA analysis peak pressure results are included in UFSAR Table 5.4-11. Table 5.4-11 in UFSAR Revision 45, which was transmitted to the NRC by a September 30, 2013 letter (Serial No.13-478), currently reflects a peak pressure value of 44.05 psig. The UFSAR is in the process of being revised to reflect the recently recalculated value of 43.95 psig. The test pressure for the Unit 1 2006 and Unit 2 2000 Type A testing was 44.46 psig.

2. Discuss the procedure used for the development of bases for new Type C testing frequencies. Discuss all the important performance factors identified, that are considered in establishing testing intervals (e.g. past performance, service design, safety impact, cause determination.)

Dominion Response: The controlling surveillance procedure for containment leak testing specifies the following regarding Type C tests:

6.1.3 Type C Tests

a. Type C tests on containment isolation valves shall be performed during a period of refueling shutdown at a frequency of at least once every 60 months based on acceptable performance history. Acceptable performance history is defined as completion of two consecutive periodic As Found Type C tests where results of each test are within the allowable limits.

If a containment isolation valve fails, the next test is required within 24 months. In addition, a cause determination should be performed and

Serial No. 13-435C Docket Nos. 50-280/281 Attachment Page 2 of 2 corrective actions identified that focus on those activities that can eliminate the identified cause of failure. Once the cause determination and corrective actions have been completed, acceptable performance may be re-established and the testing frequency returned to the extended interval.

b. Type C test scheduling shall be based on the following:

• Leakage history -- As Found minimum pathway

• ISI test requirements - stroke test (ST), leak test (LT), valve position (VP), etc.

• Maintenance Rule, if applicable Prior to each refueling outage, site engineering personnel prepare an engineering technical evaluation (ETE) that identifies the Type B and C testing requirements for the outage. The pre-outage ETE reflects testing requirements consistent with the excerpt from the controlling surveillance procedure for containment leak testing cited above.

3. Describe the post-outage scope report issued to document the local leak rate test periodically and to ensure that all pre-maintenance and post-maintenance testing is complete. Discuss how the post-outage scope report provides a written record of the extended testing interval changes and the reasons for the changes based on testing results and maintenance history.

Dominion Response: During refueling outages, the implementing leak rate testing procedures, in conjunction with the Post-maintenance Test program, are used to ensure that pre-maintenance and post-maintenance testing is completed, as required.

Additionally, if the leakage for a valve and/or penetration is determined to be unacceptable during refueling outage testing, a Condition Report in the Corrective Action Program (CAP) is initiated. Required corrective action to address unacceptable leakage is documented in the CAP, and the testing frequency is then modified.

Following each refueling outage, site engineering personnel update the Performance Based Containment Leak Test Program report. This report documents the historical as-found local leak rate test results and the required test frequency for each penetration and associated valves.