ML17255A221
| ML17255A221 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/07/2017 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML17255A221 (6) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 2326I September 7, 2017 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST 10CFR50.90 Serial No.:
17-337 SPS/LIC-CGL: RO Docket Nos.:
50-280/281 License Nos.:
DPR-32/37 REVISION OF RESIDUAL HEAT REMOVAL AND COMPONENT COOLING SYSTEM REQUIREMENTS AND ADDITION OF SURVEILLANCE REQUIREMENT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated January 20, 2017 (Serial No.17-006(ML17026A174)), Virginia Electric and Power Company (Dominion Energy Virginia) submitted a license amendment request (LAR) to revise the Technical Specification (TS) 3.5 Residual Heat Removal (RHR) System requirements, as well as the TS 3.13 RHR support requirements for the Component Cooling System, for consistency with the design basis of the RHR System.
In an August 9, 2017 e-mail from Ms. Karen Cotton Gross (NRC Project Manager) to Mr. Gary Miller (Dominion Energy Virginia Corporate Licensing), the NRC technical staff requested additional information regarding the proposed LAR. Dominion's response to the NRC request for additional information is provided in the attachment.
The information provided in this letter does not affect the conclusions of the no significant hazards consideration determination or the environmental assessment included in the January 20, 2017 LAR.
Should you have any questions or require additional Information, please contact Mr. Gary D. Miller at (804) 273-2771.
Respectfully, Mark D. Sartain Vice President Nuclear Engineering and Fleet Support COMMONWEAL TH OF VIRGINIA 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 and Fleet Support, 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 ~ day of ~~~
, 2017.
My Commission Expires: ~~
31 I a.03:-o W~1::>.~
Notary Public WANDA D. CRAFT Notary Public Commonwealth of Virginia Reg. # 7520495 My Commission Expires January 31, 20~
Commitments contained in this letter: None Serial No.17-337 Docket Nos. 50-280/281 RAI Response Page 2 of 2
Attachment:
Response to NRC Request for Additional Information -
Proposed License Amendment Request - Revision of Residual Heat Removal and Component Cooling System Requirements and Addition of Surveillance Requirement 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 - ih floor 109 Governor Street Suite 730 Richmond, VA 23219 Ms. Karen R. Cotton Gross 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 Mr. James R. Hall NRC Senior Project Manager - North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B-1A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station
Attachment Serial No.17-337 Docket Nos. 50-280/281 Response to NRC Request for Additional Information Proposed License Amendment Request Revision of Residual Heat Removal and Component Cooling System Requirements and Addition of Surveillance Requirement Virginia Electric and Power Company (Dominion Energy Virginia)
Surry Station Units 1 and 2
Serial No.17-337 Attachment Docket Nos. 50-280/281 Page 1 of 3 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION SURRY POWER STATION UNITS 1 AND 2 By letter dated January 20, 2017 (Serial No.17-006 (ML17026A174)), Virginia Electric and Power Company (Dominion Energy Virginia) submitted a license amendment request (LAR) to revise the Technical Specification (TS) 3.5 Residual Heat Removal (RHR) System requirements, as well as the TS 3.13 RHR support requirements for the Component Cooling (CC) System, for consistency with the design basis of the RHR System.
In an August 9, 2017 e-mail from Ms. Karen Cotton Gross (NRC Project Manager) to Mr. Gary Miller (Dominion Energy Virginia Corporate Licensing), the NRC technical staff requested additional information regarding the proposed LAR.
The request for additional information and Dominion's response are provided below.
Basis for the Request The licensee requested changes to the technical specifications (TSs) for Surry Power Station Units 1 and 2. Specifically, the licensee requested changes to the residual heat removal and component cooling system TS requirements.
Current TS 3.5.B states:
The requirements of Specification A may be modified to allow one of the following components (including associated valves and piping) to be inoperable at any one time. If the system is not restored to meet the requirements of Specification A within 14 days [emphasis added], the reactor shall be shutdown.
The licensee proposed to replace current TS 3.5.B with the following statement:
The requirements of Specification A may be modified as specified in Specification 3.1.A.1.d, 3.1 O.C, or 3.13.D, as applicable, and immediate action shall be taken to restore operability/operation of the out of service equipment.
Current TS 3.5.B provides a terminal action if Specification A requirements are not met within 14 days. It requires a reactor shutdown. However, the licensee's proposed new statement for TS 3.5.B does not contain a terminal action for Specification A.
Request for Additional Information Please provide a justification for not including a terminal action for TS 3.5.A.
Regulatory Basis The regulations contained in 10 CFR Part 50.36(c)(2)(i) state:
Serial No.17-337 Attachment Docket Nos. 50-280/281 Page 2 of 3 Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. When a limiting condition for operation of any process step in the system of a fuel reprocessing plant is not met, the licensee shall shut down that part of the operation or follow any remedial action permitted by the technical specifications until the condition can be met.
Dominion Response:
As stated in our letter dated January 20, 2017 (Serial No.17-006), the LAR to revise the TS 3.5 RHR System requirements, as well as the TS 3.13 RHR support requirements for the CC System, is requested for consistency with the design basis of the RHR System (i.e., to be placed in operation when the reactor coolant temperature and pressure are - 350°F and between 400 and 450 psig, respectively). As part of the LAR, the TS 3.5.A operability requirements for the RHR System are revised to refer to the operability requirements in TS 3.1.A.1.d, TS 3.10.A.4, and TS 3.10.A.5, as well as to the TS 3.13.C CC System operability requirements to supply cooling water to the* RHR heat exchangers.
The LAR also revises TS 3.5.B. The revision to TS 3.5.B retains the existing action in TS 3.5.B to take immediate action to restore operability/operation of the out of service equipment, while the existing action in TS 3.5.B to shut down the reactor within 14 days, if the system is not restored, is being deleted, along with the deletion of the applicability of reactor criticality. The revision to TS 3.5.B also refers to the requirements/actions in TS 3.1.A.1.d, TS 3.1 O.C, and TS 3.13.D, as applicable. The requirements/actions that are referred to in those specifications are as follows:
The TS 3.1.A.1.d requirements are not being revised by this LAR.
Currently TS 3.1.A.1.d requires a minimum of two non-isolated loops, consisting of any combination of reactor coolant loops or residual heat removal loops as specified. The existing requirements of TS 3.1.A.1.d are applicable when the average reactor coolant loop temperature is less than or equal to 350°F, so the reactor is already shut down (i.e., in intermediate shutdown or below) upon entry into TS 3.1.A.1.d.
The TS 3.1 O.A.4, TS 3.1O.A.5, and TS 3.10. C requirements/actions are not being revised by this LAR. Currently if the requirements in TS 3.1 O.A.4 and TS 3.1 O.A.5 for RHR pump and heat exchanger operability with the reactor already shut down (i.e., during refueling operations) are not satisfied, the action required is to enter TS 3.10.C, which requires cessation of refueling operations, placing irradiated fuel in a safe position, initiating work to correct the conditions not meeting the specified limit, and conducting no operations that would increase reactivity of the core. With the
Serial No.17-337 Attachment Docket Nos. 50-280/281 Page 3 of 3 proposed revision to TS 3.5.B, entry into TS 3.1 O.C will continue to be the action if the TS 3.1 O.A.4 or TS 3.1 O.A.5 requirements are not satisfied.
The current portion of TS 3.13.A requirements for CC System operability to supply cooling water to the RHR heat exchangers is relocated to TS 3.13.C and is revised to be applicable when the average reactor coolant temperature is less than equal to 350°F for consistency with the design basis of the RHR System.
Also for consistency with the RHR System design basis, the current portion of the TS 3.13.B action for the CC System to supply cooling water to the RHR heat exchangers is relocated to new action TS 3.13.D.
The new TS 3.13.D states that if the requirements of TS 3.13.C are not satisfied, immediate attention shall be directed at making repairs and the requirements in TS 3.1.A.1.d, TS 3.1 O.A.4 and TS 3.1 O.A.5, as applicable, shall be satisfied. The requirements/actions for those specifications are discussed in the previous bullets.
In summary, the proposed revision to TS 3.5.B retains the current action in TS 3.5.B to take immediate action to restore operability/operation of out of service RHR equipment and references the existing requirements/actions in TS 3.1.A.1.d and TS 3.10.C for the RHR System. The existing referenced requirements/actions are applicable only when the reactor is already shut down. Thus, the deletion of the shutdown requirement in TS 3.5.B is essentially replaced with the existing requirements/actions that are applicable when the reactor is shut down.
In conclusion, the action contained in the proposed revision to TS 3.5.B, along with the references to the requirements/actions in the other specifications, is appropriate and consistent with the RHR System design basis.