Text

Proposed License Amendment Request, Temporary, One Time 21-Day Allowed Outage Time for Replacement of Reserve Station Service Transformer C and Associated Cabling
	ML17317A464
Person / Time
Site:	Surry
Issue date:	11/07/2017
From:	Mark D. Sartain; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	17-435
	Download: ML17317A464 (46)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 November 7, 2017 10CFR50.90 U. S. Nuclear Regulatory Commission Serial No.: 17-435 Attention : Document Control Desk SPS/LIC-CGL: RO Washington , DC 20555-0001 Docket Nos. : 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST TEMPORARY, ONE TIME 21-DAY ALLOWED OUTAGE TIME FOR REPLACEMENT OF RESERVE STATION SERVICE TRANSFORMER C AND ASSOCIATED CABLING Pursuant to 10CFR50.90, Virginia Electric and Power Company (Domin ion Energy Virginia) is submitting a license amendment request to revise Surry Power Station (Surry) Units 1 and 2 Technical Specification (TS) 3.16, "Emergency Power System ," to provide a temporary, one-time 21 -day allowed outage time (AOT) for replacement of Reserve Station Service Transformer (RSST) C and associated cabling. Replacement of RSST C is necessary since it is original plant equipment and is reaching the end of its dependable service life. A supporting risk assessment was performed and demonstrates that the reliability of offsite power is not significantly impacted during the proposed 21-day AOT. provides discussion and evaluation of the proposed change. The Regulatory Commitment Summary is provided in Attachment 2. The marked-up and proposed pages for the TS and TS Basis are provided in Attachments 3 and 4, respectively . The TS Basis changes are provided for NRC information only.

We have evaluated the proposed amendment and have determined that it does not involve a significant hazards consideration as defined in 10CFR50 .92 . The basis for th is determination is included in Attachment 1. We have also determined that operation with the proposed change will not result in a sign ificant increase in the amount of effluents that may be released offsite or a 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 1OCRF51 .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 .

Dominion Energy Virginia requests approval of the proposed change by September 30 , 2018 with a 60-day implementation period .

Serial No.17-435 Docket Nos. 50-280/281 Page 2 of 3 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 Commitments contained in this letter: See Attachment 2.

Attachments:

1. Discussion of Change

2. Regulatory Commitment Summary

3. Marked-up Technical Specifications and Basis Pages

4. Proposed Technical Specifications and Basis Pages COMMONWEALTH 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 '7-R day of t-Jov~w , 2017.

My Commission Expires:

WANDA D. CRAFT Notary Public Notary Public Commonwealth of Virginia Reg. # 7520495 My Commission Expires January 31 , 20.le

Serial No.17-435 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 - th floor 109 Governor Street Suite 730 Richmond , VA 23219 Ms. K. 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. J. R. Hall NRC Senior Project Manager - North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B-1 A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Sen ior Resident Inspector Surry Power Station

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 DISCUSSION OF CHANGE Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Station Units 1 and 2

Serial No.17-435 Docket Nos. 50-280/281 Attach ment 1 Page 1 of 24 DISCUSSION OF CHANGE TABLE OF CONTENTS 1.0 Summary Description 2.0 Detailed Description 2.1 Existing System Design and Operation 2.2 Current Technical Specifications Requirements 2.3 Reason for Proposed Change 2.4 Description of Proposed Change 3.0 Technical Evaluation 3.1 Design Basis Configuration 3.2 Temporary, One-time, 21-day AOT Configuration 3.3 Design Analysis 3.4 Branch Technical Position 8-8 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 5.0 Precedents 6.0 Environmental Consideration 7.0 Conclusion 8.0 References 9.0 Figures

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 2 of 24 DISCUSSION OF CHANGE 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50 .90, Virginia Electric and Power Company (Dominion Energy Virginia) requests Amendments to Surry Power Station (Surry) Units 1 and 2 Facility Operating License Numbers DPR-32 and DPR-37, respectively, in the form of new License Conditions and a change to the Technical Specifications (TS). The proposed change adds a footnote to TS 3.16, "Emergency Power System," to allow a temporary, one-time extension of the Allowed Outage Time (AOT) in TS 3.16 Action B.2 from 7 days to 21 days. The requested temporary, one-time, 21-day AOT is needed to allow replacement Reserve Station Service Transformer C (RSST-C) and associated cabling during the Surry Unit 2 fall 2018 refueling outage. The associated TS 3.16 Basis will also be revised to include the basis for the temporary, one-time, 21-day AOT.

2.0 DETAILED DESCRIPTION 2.1 Existing System Design and Operation (Refer to Figures 9.1, 9.2, and 9.3 for the following descriptions.)

Each Surry unit has two (2) independent 4, 160V emergency buses and associated switchgear. Buses 1H and 1J supply the Unit 1 safety-related loads, and buses 2H and 2J supply the Unit 2 safety-related loads. Each bus is sized to carry 100% of the emergency load .

The safety-related buses are supplied by the Reserve Station Service Transformers (RSSTs) during all modes of operation (normal , start-up and shutdown). There are three RSSTs. Each RSST is sized to start up a single unit or shutdown both units.

RSST-A supplies bus 1J, RSST-B supplies bus 2H, and RSST-C supplies buses 1H and 2J [Ref. 8.1].

The RSSTs are supplied by the System (Switchyard) Reserve Transformers (SRTs) .

The SRTs are designated as the primary offsite power sources. There are three (3)

SRTs; SRT-1 supplies RSST-A and/or RSST-B, SRT-2 supplies RSST-C, and SRT-4 can supply RSST-A and/or RSST-B, or RSST-C .

The SRTs are supplied with offsite power from two independent switchyards ; the 500 kV switchyard supplies SRT-1, and the 230 kV switchyard supplies SRT-2 and SRT-4.

Offsite power can be supplied to SRT-1 from three (3) independent sources. Offsite power can be supplied to SRT-2 and SRT-4 from ten (10) independent sources [Ref.

8.1]. Thus, the offsite power supplies are redundant, robust, and diverse.

To ensure the possibility of two-unit simultaneous loading of the reserve station service (RSS) system is maintained within its design capability, a load shedding system was installed to remove the overloads on the RSS system . This system provides for

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 3 of 24 automatic load shedding of selected non-safety-related loads from both units, which limits RSST loading to under 4000A per transformer. The scheme ensures that voltages available on the emergency buses will be within acceptable limits. A manual override switch is provided in the control room to allow manual restarting of the shed loads in a controlled manner.

Normal Outage Configuration (Refer to Figures 9.1 , 9.2, and 9.3 for the following descriptions.)

The RSST power for the auxiliaries of either unit is normally supplied from SRT-1 (which is the 500/36.5-kV transformer that is connected to the 500-kV Bus 1), SRT-2 (which is the 230/36.5-kV transformer that is connected to the 230-kV Bus 4) or SRT-4 (which is the 230/36.5-kV transformer that is connected to the 230-kV Bus 3) . The 500-kV and 230-kV systems are independent and provide alternative sources of reserve power.

An operating unit is required to have both 4160V Emergency Buses (1 H and 1J) energized from separate primary circuits from the offsite transmission network. The TS Basis defines the primary circuits as SRTs 1, 2 and 4. Emergency Bus 1J is normally supplied by SRT-1 via Transfer Bus D and RSST-A. Emergency Bus 1H is normally supplied by SRT-2 via Transfer Bus F and RSST-C .

Electric power requirements for a unit undergoing refueling are not as explicitly stated.

However, Emergency Bus 2H is normally supplied by SRT-1 via Transfer Bus E and RSST-B , and Emergency Bus 2J is normally supplied by SRT-2 via Transfer Bus F and RSST-C .

Any emergency bus (1H , 1J, 2H , 2J) may be supplied by SRT-4 via buses D, E, and F via RSST-A and/or RSST-B , or RSST-C .

The second , independent power source is called the "dependable alternate" source.

This source does not typically provide the unit with alternate power but can be made available within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if requ ired .

2.2 Current Technical Specifications Requirements TS 3.9, "Station Service Systems", requires the following :

3.9.A.1 : A unit's reactor shall not be made critical without all three of the unit's 4,160V buses energized .

3.9.A.5: Both of the 4,160V emergency buses energized as explained in Section 3.1 6.

TS Action 3.16.B.2 requires that the un it be brought to cold shutdown after 7 days if (a)

"a primary source is not available" or (b) "specification A-4 is not satisfied ".

A primary source is defined as a circuit that supplies power through the Reserve Station Service Transformers (RSSTs) . The circuits that supply power through

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 4 of 24 the RSSTs are from three (3) System (Switchyard) Reserve Transformers (SRTs) .

o SRT No. 1 (which is the 500/36 .5-kV transformer that is connected to 500-kV Bus 1) o SRT No. 2 (which is the 230/36 .5-kV transformer that is connected to 230-kV Bus 4) o SRT No. 4 (which is the 230/36.5-kV transformer that is connected to 230-kV Bus 3)

The 500-kV and 230-kV systems are independent and provide alternative sources of reserve power [Ref. 8.1].

Specification 3.16 .A.4 requires two physically independent circuits from the offsite transmission network to energize the 4, 160V and 480V emergency buses .

o "One of these sources must be immediately available (i.e., primary source) ."

As defined above, the primary source must come from SRT Nos. 1, 2, or 4 through an RSST.

o "The other must be capable of being made available within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (i.e. ,

dependable alternate source). "

The dependable alternate source can be made available in eight (8) hours by removing the unit from service, disconnecting its generator from the isolated phase bus, and feeding offsite power through the main step-up transformer and normal station service transformer to the emergency buses.

2.3 Reason for Proposed Change The existing RSST-C is original plant equipment and is reaching the end of its dependable service life. Replacement of RSST-C will assure continued dependable and safe generation of electrical power. The proposed temporary 21-day AOT is needed to allow sufficient time to replace RSST-C and associated cabling while permitting Unit 1 to maintain normal power operation . The temporary 21-day AOT also precludes the unnecessary transient of shutting down Unit 1 and the attendant risk . The RSST-C installation activity includes replacement of components that support RSST operation ,

including associated cabling , the load tap changer, monitoring equipment, overhead disconnect switches , sudden pressure relays , and protective relays. A detailed evaluation of the proposed RSST-C installation activities determined that 21 days is sufficient time to complete the installation , with margin . The requested temporary, one-time, 21-day AOT will be implemented during the fall 2018 Unit 2 refueling outage.

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 5 of 24 2.4 Description of Proposed Change Dominion Energy Virginia proposes to add Operating License Conditions, temporary ,

one-time, Technical Specifications requirements , and additional wording to the TS Basis as follows :

Operating License Condition Item V. is to be added to the Surry Units 1 and 2 Operating Licenses:

V. As discussed in the footnote to Technical Specification 3.16.B.2, the use of a temporary 21-day allowed outage time will permit Unit 1 to continue to operate for 21 days during the fall 2018 Unit 2 refueling outage to facilitate replacement of Reserve Station Service Transformer C and associated cabling (

Reference:

Letter Serial No.17-435, dated November 7, 2017) .

TS 3.16.B.2 is to be revised to add a one-time extension of the primary source Allowed Outage Time from 7 days to 21 days:

B. During POWER OPERATION or the return to power from HOT SHUTDOWN ,

the requirements of specification 3.16.A may be modified by one of the following :

2. If a primary source is not available, the unit may be operated for seven (7) days provided the dependable alternate source can be OPERABLE within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . If specification A-4 is not satisfied within seven (7) days , the unit shall be brought to COLD SHUTDOWN. (*)

(*) To facilitate replacement of the Reserve Station Service Transformer C and associated cabling during the fall 2018 Unit 2 refueling outage, the use of a temporary, one-time, 21-day allowed outage time (AOT) is permitted for the unavailability of a primary source . Prior to entry into and during the 21-day AOT, the following actions shall be taken :

Within 30 days prior to entering the temporary 21-day AOT, functionality of the Alternate AC (AAC) System (i.e., the supplemental power source) shall be verified .

During the 21 -day AOT , the functionality of the AAC System shall be checked once per shift. If the AAC System becomes non-functional at any time during the 21-day AOT, it shall be restored to functional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the unit shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 6 of 24 TS 3.16 Basis is to be revised in support of the temporary footnote to TS 3.16.B.2:

Reserve Station Service Transformer (RSST) C is the primary offsite power source for the 1Hand 2J Emergency Buses via Transfer Bus F. To facilitate the replacement of RSST-C and associated cabling during the fall 2018 Unit 2 refueling outage , Technical Specification 3.16.B .2 is modified by a footnote permitting the use of a temporary, one time, 21-day allowed outage time (AOT) . The 21-day AOT will permit Unit 1 to continue to operate for 21 days. While RSST-C is unavailable during replacement, Transfer Bus F will be powered from the dependable alternate source (i.e. , backfeed through the Unit 2 Main Step-up Transformer/2C Station Service Transformer). The backfeed power supply will allow Transfer Bus F to perform its normal function while RSST-C is being replaced. Prior to entry into and during the 21-day AOT, the following actions shall be taken:

1. Within 30 days prior to entering the temporary 21-day AOT, functionality of the Alternate AC (AAC) System (i.e., the supplemental power source) shall be verified.

2. During the 21-day AOT, the functionality of the AAC System shall be checked once per shift. If the AAC System becomes non-functional at any time during the 21-day AOT, it shall be restored to functional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the unit shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The verification of functionality of the AAC System prior to entering the temporary 21-day AOT will be based on the previous satisfactory quarterly test. The once per shift functionality check will be performed during shiftly operator rounds.

In addition to verifying and checking functionality of the AAC System prior to and during the temporary 21-day AOT, the following actions will be taken :

Weather conditions will be monitored and preplanned maintenance will not be scheduled if severe weather conditions are anticipated .

The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the temporary 21-day AOT.

Component testing or maintenance of safety systems and important non-safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided . In addition , no discretionary switchyard maintenance will be performed .

TS required systems, subsystems, trains , components, and devices that depend on the remaining power sources will be verified to be operable and positive

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 7 of 24 measures will be provided to preclude subsequent testing or maintenance activities on these systems, subsystems, trains, components, and devices.

Operation or maintenance of plant equipment when its redundant equipment or tra in is out of service will be controlled in accordance with procedure OP-SU-601 ,

"Protected Equipment". The Unit 1 steam-driven Auxiliary Feedwater Pump will be controlled as "Protected Equipment" during the temporary 21-day AOT.

The status of the AAC diesel generator, EDGs , RSST-A and RSST-B will be monitored once per shift.

3.0 TECHNICAL EVALUATION

Two independent 4160V emergency buses and switchgear are provided for each Surry unit. Each bus is sized to carry 100% of the emergency load and may be energized by either onsite or offsite power supplies . The onsite and offsite power supplies are both independently capable of supplying power to the Engineered Safeguards Features (ESF) equipment. This capability is maintained even in the event of a failure of any single active component in either system .

3.1 Design Basis Configuration Dominion performed analyses in accordance with NRC Generic Letter 79-36 , dated August 8, 1979, entitled "Adequacy of Station Electrical Distribution System Voltages ,"

to determ ine the adequacy of the Surry electrical distribution system. As described in UFSAR Section 8.5, the review consisted of:

1. Analytically determining the capacity and capability of the offsite power system and onsite distribution system to automatically start as well as operate all required loads within their required voltage ratings in the event of: (1) an anticipated transient, or (2) an accident (such as a LOCA) without manual shedding of any electric loads.

2. Determining if there are any events or conditions which could result in the simultaneous or consequential loss of both required circuits from the offsite network to the onsite electrical distribution system and thus violate the requirement of General Design Criterion 17.

The analyses concluded that the Surry Units 1 and 2 offsite power system and the onsite distribution system are capable of providing acceptable voltages for worst-case station electric load and grid voltages .

The voltage level and current loading of the station distribution buses are displayed in the control room . The status of the switchyard breakers and the source of reserve station power are read ily available to the operator. Indicating lights show the source of power to each bus. Alternate sources may be manually selected by the operator, but prearranged automatic transfer takes place on failure of the normal source .

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 8 of 24 Thus the existing configuration is capable of supporting the emergency loads, with allowance for a single failure, under worst-case conditions. As discussed in the design analysis section , substituting the Unit 2 dependable alternate source for one primary source during the fall 2018 Surry Unit 2 refueling outage (temporary, one-time , 21-day AOT configuration) does not compromise this capability.

3.2 Temporary, One-time, 21-day AOT Configuration During the temporary 21-day AOT, Unit 1 will be in the POWER OPERATION mode and Unit 2 will be in the COLD SHUTDOWN, REFUELING SHUTDOWN, or REFUELING OPERATION mode with RSST-C out-of-service . The AOT configuration maintains redundant and physically separate offsite primary power supplies to Transfer Buses D (via RSST-A) and Evia (RSST-B) (Figures 9.2 and 9.3) . The only difference is the AOT configuration replaces the normal primary power supply to Transfer Bus F (normally via RSST-C) with a single offsite backfeed through the Unit 2 Main Step-up Transformer and Station Service Transformer SS-TX-2C. Thus, Emergency Buses 1H, 1J, 2H , and 2J are energized from an offsite power source in accordance with TS 3.9 . However, Emergency Buses 1H and 2J are fed from the dependable alternate source instead of a primary source. As discussed in the design analysis section , the AOT configuration is capable of supporting the emergency loads, with allowance for a single failure, under worst-case conditions.

The operating unit (Unit 1) will maintain a preferred offsite supply for Emergency Bus 1J from the 230 kV switchyard (SRT-4 to bus 7 to RSST-A) to ensure that a failure in the 500 kV switchyard cannot affect both Unit 1 Emergency Buses (1J and 1H) . The supply for Emergency Bus 1H will be from the Unit 2 designated dependable alternate source (offsite power from the 500 kV switchyard through the Main Step-up Transformer and normal Station Service Transformer SS-TX-2C to Transfer Bus F to Emergency Bus 1H) .

The refueling unit (Unit 2) will maintain a preferred offsite supply for Emergency Bus 2H from the 230 kV switchyard (SRT-4 to bus 7 to RSST-B) to ensure that a failure in the 500 kV switchyard cannot affect both Unit 2 Emergency Buses (2J and 2H) . The supply for Emergency Bus 2J will be from the Unit 2 designated dependable alternate source (offsite power from the 500 kV switchyard through the Unit 2 Main Step-up Transformer and normal Station Service Transformer SS-TX-2C to Transfer Bus F to Emergency Bus 2J) .

During the temporary 21-day AOT, the one-time only configuration and operating restrictions are as follows :

1. Two Unit Load Shed Circuit (LSR1) defeated .

2. Auto Start Blocking circuit (LSR2) in operation .

3. RSST-C out of service .

4. Transfer Bus D supplied by RSST-A (Bus 1J and normal configuration and loads).

5. Transfer Bus E supplied by RSST-B (Bus 2H and normal configuration and loads).

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 9 of 24

6. Transfer Bus F supplied by Unit 2 Station Service Transformer SS-TX-2C (AOT configuration) with the following loads:

Bus 1H: normal operating load .

Bus 2J: normal outage load plus Residual Heat Removal (RHR) pump.

Bus 1C: will transfer to Bus F if unit trips.

Bus 2C: Feedwater pump (uncoupled) , Condensate , Bearing Cooling pump, 480V lighting - on; Reactor Coolant Pump, High Pressure Heater Drain , Low Pressure Heater Drain - off.

Thus, in the one-time AOT configuration the dependable alternate source (Unit 2 backfeed) is immediately available (i.e., it does not require an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months window for connection), because it is already connected for the Unit 2 refueling outage, and the onsite power supplies remain available to Emergency Buses 1H and 2J because onsite power supplies to Transfer Bus Fare downstream of RSST-C .

Defense-In-Depth is preserved because each emergency bus is continuously supplied from a physically and electrically independent offsite source, each emergency bus can be supplied by an emergency diesel generator, and each switchyard (230 kV and 500 kV) has multiple sources of offsite power.

3.3 Design Analysis There are two (2) emergency buses for each unit; buses 1Hand 1J (Unit 1), and buses 2H and 2J (Unit 2) [Ref. 8.1]. During the temporary 21-day AOT, while RSST-C is being replaced, buses 1J and 2H will continue to be energized from SRT-4, which is a designated primary offsite power source. Buses 1H and 2J will be energized from Main Step-up Transformer 2, which is the Unit 2 designated dependable alternate source.

While this is a reliable source, which is from a separate switchyard and is capable of supporting the combined Unit 1 and Unit 2 loads, it is not a designated primary source.

Under these conditions, Technical Specification (TS) 3.9 is met, but TS 3.16 .B.2 would normally require that Unit 1 be brought to COLD SHUTDOWN after 7 days into the RSST-C replacement activities . However, since Emergency Buses 1Hand 2J will continue to be supplied by a separate and reliable power source , and the other features of the offsite and onsite power systems are unchanged and unaffected, it is reasonable and prudent to request a temporary 21-day AOT on a one-time basis to eliminate the need for an unnecessary Unit 1 transient (i.e., bringing Unit 1 to COLD SHUTDOWN until RSST-C is returned to service) .

For the AOT, Emergency Buses 1H and 2J will be fed from the Unit 2 dependable alternate source . Buses 1J and 2H will be supplied from the circuits between the offsite transmission network and the onsite Class 1-E electrical power distribution system as identified in Table 3.3-1 below. (See Figures 9.1 , 9.2, and 9.3.)

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 10 of 24 Table 3.3-1: Temporary 21-day AOT Available Offsite Power Circuits Emergency Available Transmission Station Available Offsite Power Circuits Bus Alignments Network Transformer Temporary 21-day 500 kV Main Step-up Transformer (MT) 2 =>SST Bus 1H AOT Only Switch yard 2C =>Transfer Bus F=> Emergency Bus N/A 1H Primary Offsite 500 kV SRT 1 => RSST-A=> Transfer Bus D=>

Bus 1J SRT-1 Source* Switch yard Emergency Bus 1J Alternate Offsite 230 kV SRT 4 => RSST-A=> Transfer Bus D=>

SRT-4 Source* Switch yard Emergency Bus 1J Dependable Alternate 230 kV MT 1 =>SS TX 1A =>Transfer Bus D=>

N/A Offsite Source Switchvard Emerqencv Bus 1J Primary Offsite 500 kV SRT 1 => RSST-B=> Transfer Bus E=>

Bus 2H SRT-1 Source* Switchyard Emerqencv Bus 2H Alternate Offsite 230 kV SRT 4 => RSST-B=> Transfer Bus E=>

SRT-4 Source* Switch yard Emergency Bus 2H Dependable Alternate 500 kV MT 2 => SS TX 2B =>Transfer Bus E=>

N/A Offsite Source Switch yard Emerqencv Bus 2H Temporary 21-day 500 kV MT 2 =>SST 2C =>Transfer Bus F=>

Bus 2J N/A AOT Only Switchvard Emerqencv Bus 2J Table 3.3-1 Note

During the temporary 21-day AOT, in order to maintain separation between the qualified offsite sources, buses 1J and 2H will be supplied from the 230 kV switchyard (230 kV switchyard offsite source SRT-4) instead of the 500 kV switchyard (500 kVoffsite source SRT-1).

ESF equipment will continue to be powered from two independent emergency buses.

Should all offsite power sources fail, reliable onsite power is ensured by the emergency diesel generators (EDGs) and/or the AAC System. ESF equipment can be manually operated from the control room .

Each emergency bus provides power to the following ESF equipment:

1. One Containment Spray Pump

2. One Charging Pump (100% capacity)

3. One Low-Head Safety Injection Pump (100% capacity)

4. One Inside Recirculation Spray Pump (100% total capacity)

5. One Outside Recirculation Spray Pump (100% total capacity)

6. One Motor Driven Auxiliary Feedwater Pump

7. One Motor Control Center for valves, instruments, control air compressor, fuel oil pumps, etc.

8. Control Area HVAC equipment (two air recirculating units, one water chilling unit, one service water pump, and one chilled water circulating pump)

9. One Charging Pump Service Water Pump In addition, as described in UFSAR Section 8.4.1, a load shedding scheme is currently implemented to alleviate potential low-voltage profile conditions during combined Units 1 and 2 operation using the RSSTs only. The existing load shedding scheme is not altered by the AOT configuration.

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 11 of 24 Nevertheless, in order to provide additional protection for the offsite power supplies to the emergency power buses, restrictions will be imposed while the emergency buses are in the temporary 21-day AOT configuration , as described in Section 3.2 .

3.4 Branch Technical Position (BTP) 8-8 The NRC has provided the requirements for onsite and offsite power sources AOT extensions in BTP 8-8 [Ref. 8.2].

Risk Assessment "Consistent with the Commission 's final policy statement, it is expected that a license amendment request for an onsite or offsite AOT extension will contain a PRA assessment."

A risk assessment has been performed for the temporary, one-time, 21-day AOT configuration . A fault tree analysis was used to assess the reliability of offsite power supplies to Transfer Bus F and to evaluate conditional reliability in a configuration where the primary offsite supply from RSST-C is unavailable. The assessment provided the following risk insights:

The overall reliability of offsite power supply to Transfer Bus F is only marginally affected by unavailability of RSST-C . This is because catastrophic grid and weather disturbances are the dominant contributors to Transfer Bus F reliability (90% of unreliability) . These contributors have the consequence of rendering all offsite power supplies to Transfer Bus F unavailable for extended periods of time, regardless of the number of available connections from the switchyard to Transfer Bus F.

The overall probability that all offsite power would be lost to Transfer Bus F during a 21-day period is very low (estimated to be approximately 5E-04) . There are no components in these offsite sources that have high unreliability.

Station Defense-in-Depth to loss of offsite power is not significantly impacted by rendering the primary RSST-C power supply unavailable. In addition to the two alternate backfeed power supplies, two EDGs are available to respond to a loss of power to Transfer Bus F. Transfer Buses D and E are also available to provide power to the 100% redundant 1J and 2H Emergency Buses .

No unique vulnerabilities were identified with alternate backfeed power sources which require special attention .

This assessment demonstrates that the reliability of offsite power to Transfer Bus F is not significantly impacted in a configuration where the primary offsite source via RSST-C is unavailable and supports the proposed temporary 21-day AOT.

During the 21-day temporary AOT, the increase in risk will be assessed and managed in accordance with the requirements of 10 CFR 50 .65(a)(4). Online risk for Surry Unit 1 will be assessed using a PRA model dedicated to the purpose of performing

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 12 of 24 configuration risk analysis. Shutdown risk for Surry Unit 2 will be managed in accordance with Surry's shutdown risk management program . Configurations that approach or exceed the limits defined in NUMARC 93-01 are identified and either avoided or addressed by risk management actions. Emergent configurations are identified and analyzed by the on-shift staff for prompt determination of whether risk management actions are needed .

Defense-In-Depth, AAC Supplemental Power Source

'}'.\ supplemental power source should be available as a backup to the inoperable EOG or offsite power source, to maintain the defense-in-depth design philosophy of the electrical system to meet its intended safety function ."

In response to 10 CFR 50 .63, the Alternate AC (AAC) system was installed to provide ac power to one emergency bus on each unit during a Station Blackout (SBO) event.

The AAC System is non-safety related and is designed in accordance with Regulatory Guide 1.155 and NUMARC 87-00, Appendix B.2.

As described in UFSAR Section 8.4.6, the electrical design consists of a single 4160V ac diesel driven generator with a continuous rating of 3300 kW and a 2000-hour rating of 3640 kW. The generator is connected to the station via 4 kV buses OM and OL. Bus OL is located in the Unit 2 normal switchgear room and provides connection from bus OM to Transfer Buses D and E, which in turn allows connection to Emergency Buses 1J and 2H, respectively. The diesel generator can provide power to the emergency buses within 10 minutes of determining that an SBO event has occurred and is sized to carry the loads necessary to bring both units to a safe shutdown condition and maintain them in a safe shutdown condition for the postulated 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SBO event duration.

Following the loss of power on either Transfer Bus Dor E in conjunction with the loss of power on Transfer Bus F, the diesel generator receives an automatic start signal.

Momentary trip signals to breakers associated with the OM and OL buses ensure that the AAC System is initially isolated. Once the generator has reached proper speed and voltage, breakers automatically close to power buses OM and OL. Manual action is then required to energize Transfer Buses Dor E. The normal power supply to the Technical Support Center (TSC) uninterruptible power supply (UPS) and the TSC motor control center (MCC) is the "2C2" Load Center that can be supplied by the 2 "C" Station Service Transformer or from Reserve Station Service Transformer "C"(not available during AOT) via Transfer Bus "F." Following a loss of the normal power supply, the TSC UPS can be powered from the AAC System via either Transfer Bus Dor E following manual breaker re-alignment. Following a loss of the normal power supply, the TSC MCC can be powered from the AAC System via Transfer Bus D following manual breaker re-alignment.

The AAC diesel generator is independent from the emergency diesel generators. The AAC diesel generator and its auxiliaries are housed in a separate building located south of the Radwaste Facility. The air start system contains sufficient capacity for 5 starts and the fuel oil system for the AAC diesel contains sufficient fuel to operate the diesel generator at 3640 kW for the postulated 4-hour SBO duration. To maintain the system in a standby state , a keep warm system consisting of a jacket water heater with a

Serial No.17-435 Docket Nos. 50-280/2 81 Attachment 1 Page 13 of 24 circulating pump and a lube oil heater with a circulating pump . An ungrounded 125V de system is provided for the 4 kV and 480V ac switchgear controls, diesel generator controls , and generator protection .

The temporary 21-day AOT configuration does not challenge the defense-in-depth provisions for a loss of offsite power. As shown in Figure 9.2, each emergency bus will continue to be backed up by an EOG and/or the AAC System DG .

a) Emergency Bus 1J is backed up by EOG 3 and the AAC DG b) Emergency Bus 1His backed up by EOG 1 c) Emergency Bus 2H is backed up by EOG 2 and the AAC DG d) Emergency Bus 2J is backed up by EOG 3 Temporary 21-day AOT Duration The requested temporary, one-time, 21 -day AOT is needed to replace RSST-C and associated cabling . The estimated time to complete the replacement is approximately 17 days as shown in the schedule below.

Table 3.4-1 : Activity Schedule for Replacement of RSST-C and Associated Cabling Activity Activity Duration Elapsed Time Activity Description No. (Days - Hours) (Days - Hours) 1 Enter temporary 21-day AOT - 0-0 2 Tagout and disconnect 3-0 3-0 3 Pilot wire changes 4-0 7-0 Replace RSST C (2 day 4 7-8 12 - 8 overlap with Activity No. 3)

Testing and exit temporary 5 4 - 14 16 - 22 21-day AOT LOOP Coping Capability During Temporary 21 -day AOT The capabilities for coping with a loss of offsite power (LOOP) are not affected by the temporary 21-day AOT configuration .

Information Notice 85-91 , Load Sequencers for Emergency Diesel Generators ,

identified a potential problem with the diesel loading sequence if a LOOP should occur subsequent to a LOCA. Dominion Energy Virginia evaluated this situation with respect to EOG loading even though the Surry licensing basis considers the LOOP to occur coincident with the LOCA. The evaluation identified that, after implementation of appropriate modifications to emergency diesel sequencing logics, a LOOP subsequent to a LOCA would not result in overloading of the EDGs.

SBO Coping Capability During Temporary 21-day AOT The capabilities for coping with an SBO are not affected by the AOT configuration .

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 14 of 24 As discussed above, the AAC is capable of providing power to the emergency buses within 10 minutes of determining that an SBO event has occurred and is sized to carry the loads necessary to bring both units to a safe shutdown condition and maintain them in a safe shutdown condition for the postulated 4-hour SBO event duration .

Surveillance Testing "The TS must contain Required Actions and Completion Times to verify that the supplemental AC source is available before entering extended AOT. "

The following requirements have been included in the temporary 21 -day AOT footnote to TS 3.16.B.2:

Within 30 days prior to entering the temporary 21-day AOT, functionality of the Alternate AC (AAC) System (i.e. , the supplemental power source) shall be verified .

During the 21-day AOT, the functionality of the AAC System shall be checked once per shift. If the AAC System becomes non-functional at any time during the 21-day AOT, it shall be restored to functional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the unit shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The verification of functionality of the AAC System prior to entering the temporary 21-day AOT will be based on the previous satisfactory quarterly test. The once per shift functionality check will be performed during shiftly operator rounds .

Regulatory Commitments Additionally, the staff expects that the licensee will provide the following Regulatory Commitments:

The regulatory commitments required by BTP 8-8 are included in Attachment 2.

4.0 REGULATORY EVALUATION

As noted above, the proposed change revises the Surry Units 1 and 2 TS to include a temporary, one-time, 21-day AOT for the primary offsite power source to provide sufficient time for the replacement of RSST-C and associated cabling during the fall 2018 Unit 2 refueling outage. The temporary AOT will permit Unit 1 power operation to continue while RSST-C and associated cabling and equipment are replaced .

4.1 Applicable Regulatory Requirements/Criteria The regulations in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR)

Part 50 establish minimum principal design criteria for water-cooled nuclear power plants, while 10 CFR 50 Appendix B and the licensee quality assurance programs establish quality assurance requirements for the design , manufacture, construction , and operation of structures , systems, and components. The current regulatory requirements of 10 CFR 50 Appendix A applicable to the proposed change GDC 5 (Sharing of

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 15 of 24 Structures, Systems, and Components) , GDC 17 (Electric Power Systems), and GDC 18 (Inspection and Testing of Electric Power System).

During the initial plant licensing of Surry Units 1 and 2, it was demonstrated that the design of the Surry electrical distribution system met the regulatory requirements in place at that time. The draft GDC published in 1967 included Criterion 4 (Sharing of Systems) and Criterion 39 (Emergency Power for Engineered Safeguards), which are pertinent to the proposed change. The GDC included in Appendix A to 10 CFR 50 did not become effective until May 21 , 1971. The Construction Permits for SPS Units 1 and 2 were issued prior to May 21 , 1971; consequently, Surry Units 1 and 2 were not subject to current GDC requirements (SECY-92-223 , dated September 18, 1992).

However, subsequent reviews of Surry considered the current GDC 5, GDC 17, and GDC 18 requirements .

GDC 5 - Sharing of Structures. Systems. and Components "Structures, systems, and components important to safety shall not be shared between nuclear power Units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions including, in the event of an accident in one Unit, an orderly shutdown and cooldown of the remaining Unit."

GDC 17 - Electric Power Systems "An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to ensure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences, and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents .

The onsite electric power sources, including the batteries, and the onsite electrical distribution system, shall have sufficient independence, redundancy , and testability to perform their safety functions, assuming a single failure .

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electrical power circuit, to ensure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded . One of these circuits shall be designed to be available within a few seconds following a loss of coolant accident to ensure that core cool ing, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 16 of 24 by the nuclear power Unit, the loss of power from the transmission network, or the loss of power from the onsite electrical power supplies."

GDC 18 - Inspection and Testing of Electric Power System "Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features , such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems , such as onsite power sources , relays , switches, and buses and (2) the operability of the systems as a whole and , under conditions as close to design as practical , the full operational sequence that brings the systems into operation , including operation of applicable portions of the protection system and the transfer of power among the nuclear power Unit, the offsite power system, and the onsite power system ."

Additional references include:

NRC Reg. Guide 1.93 , "Availability of Electric Power Sources," dated December 1974

[Ref. 8.4]

NRC Reg. Guide 1.155, "Station Blackout," dated August 1988 [Ref. 8.3]

NUREG-0800, Branch Technical Position 8-8 , "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions" [Ref. 8.2]

Analysis The temporary 21-day AOT allows the dependable alternate power source to supply Transfer Bus F instead of the normal primary offsite power source. There are no other changes regarding the onsite and offsite power supplies.

The regulatory position in Reg . Guide 1.93 when " ... available offsite ac power sources are one less than the LCO," is based on the following regulatory assumption :

This degradation level means that one of the required offsite ac sources is not available, and therefore, the offsite ac power system has no redundancy.

However, full redundancy for Unit 1 continues to be maintained because (a) one primary offsite power source is connected to the 230 kV switchyard (Emergency Bus 1J via RSST-A) , and (b) one designated reliable offsite power supply is connected to the 500 kV switchyard (Emergency Bus 1H via the Unit 2 backfeed), which confirms both its operability and continued availability. The functionality of the SRT-4 transformer to the RSST-A circuit will be confirmed less than 30 days before establishing the AOT configuration .

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 17 of 24 No Significant Hazards Consideration Pursuant to 10 CFR 50 .90, Virginia Electric and Power Company (Dominion Energy Virginia) requests amendments to Surry Power Station (Surry) Units 1 and 2 Facility Operating License Numbers DPR-32 and DPR-37, respectively, in the form of new License Conditions and a change to the Technical Specifications (TS). The proposed change adds a footnote to TS 3.16, "Emergency Power System ," to allow a one-time extension of the Allowed Outage Time (AOT) in TS 3.16 Action B.2 from 7 days to 21 days. The requested temporary 21-day AOT is needed to replace Reserve Station Service Transformer C (RSST-C) and associated cabling during the Surry Unit 2 fall 2018 refueling outage. The existing RSST-C is original plant equipment and is reaching the end of its dependable service life. Replacement of RSST-C will assure continued dependable and safe generation of electrical power. The proposed temporary 21-day AOT is needed to allow sufficient time to replace RSST-C and associated cabling while permitting Unit 1 to maintain normal power operation . The temporary 21-day AOT also precludes the unnecessary transient of shutting down Unit 1 and the attendant risk.

In accordance with the criteria set forth in 10 CFR 50.92, Dominion Energy Virginia has performed an analysis of the proposed TS change and concluded that it does not represent a significant hazards consideration. The following discussion is provided in support of this conclusion :

i. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change adds a footnote to TS 3.16 , "Emergency Power System, " to allow a one-time extension of the AOT in TS 3.16 Action B.2 from 7 days to 21 days to facilitate the replacement of RSST-C and associated cabling.

During the temporary 21-day AOT, the station emergency buses will continue to be fed from redundant, separate, reliable offsite sources that are capable of supporting the emergency loads under worst-case conditions considering a single failure .

There are two (2) emergency buses for each unit: Buses 1 H and 1J (Unit 1), and Buses 2H and 2J (Unit 2) . While RSST-C is being replaced during the temporary 21- day AOT , Buses 1J and 2H will continue to be energized from a designated primary offsite source, System (Switchyard) Reserve Transformer (SRT) 4. Buses 1Hand 2J will be energized from Main Step-up Transformer 2, which is the Unit 2 designated dependable alternate source.

In both configurations Transfer Bus F is fed through two , in series, transformers.

The normal configuration feeds Transfer Bus F from the 230 kV switchyard via two (2) transformers (SRT-2 and RSST-C) and two (2) breakers . The 230 kV switchyard is connected to ten (10) offsite circu its .

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 18 of 24

The temporary 21-day AOT configuration feeds Transfer Bus F from the 500 kV switchyard via two (2) transformers (Main Step-up Transformer 2 and Station Service Transformer 2C) and three (3) breakers . The 500 kV switchyard is connected to 3 offsite circuits.

A risk assessment has been performed for the temporary 21-day AOT configuration .

The assessment concluded that the probability of a loss of offsite power for the proposed configuration is very low. Thus, the proposed change does not significantly increase the probability of an accident previously evaluated because: (a) the emergency buses continue to be feed from redundant, separate, reliable offsite sources and (b) the effect of the proposed configuration on the probability of a loss of offsite power is very low.

There is no increase in the consequences of an accident because the emergency buses continue to be fed from redundant, separate, reliable offsite circuits and the onsite power sources (i.e., the Emergency Diesel Generators) are unaffected.

The consequences of both a Loss of Offsite Power (LOOP) and a Station Blackout (SBO) have been evaluated in the UFSAR. There is no change in the station responses to a LOOP or an SBO as a result of the extended AOT because RSST-C is not included in designated equipment used in the LOOP and SBO coping strategies.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated .

11. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed configuration does not result in a change in the manner in which the electrical distribution subsystems downstream of RSST-C provide plant protection .

During the temporary AOT (21 days total), the only change is to substitute the reliable Unit 2 designated dependable alternate source for a primary offsite power source for Emergency Buses 1H and 2J . Other sources of offsite and onsite power are unaffected , and other aspects of the offsite and onsite power supplies are unchanged and unaffected.

There are no changes to the other RSSTs or to the supporting systems operating characteristics or conditions .

There is no change in the station responses to a LOOP or an SBO because RSST-C is not included in the designated equipment used in the LOOP and SBO coping strategies .

Therefore, the proposed change does create the possibility of a new or different kind of accident from any accident previously evaluated .

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 19 of 24 iii. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed TS change does not affect the acceptance criteria for any analyzed event, nor is there a change to any safety limit. The proposed TS change does not affect any structures, systems or components or their capability to perform their intended functions . The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined . Neither the safety analyses nor the safety analysis acceptance criteria are affected by this change. The proposed change will not result in plant operation in a configuration outside the current design basis as the design basis includes use of the Unit 2 dependable alternate source . The proposed TS change allows use of the Unit 2 dependable alternate power source as the primary source for buses 1H and 2J for a period of up to 21 days. The margin of safety is maintained by maintaining the capability to supply Emergency Buses 1H and 2J with a redundant, separate, reliable offsite power source, and maintaining the onsite power sources in their design basis configuration . Therefore, the proposed change does not involve a significant reduction in margin of safety.

Based on the discussion above, Dominion Energy Virginia concludes that the proposed TS change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a determination of "no significant hazards consideration" is justified.

5.0 PRECEDENTS On September 18, 2013, the NRC issued Amendment No. 160, Docket Nos. 50-445 and 50-446, to Comanche Peak Units 1 and 2, respectively. The amendments revised TS 3.8.1, "AC Sources - Operating," to allow two 14-day completion times for offsite power supplies [Ref. 8.5].

On December 23 , 2016, the NRC issued Amendment No. 199, Docket No. 50-530 , to Palo Verde Unit 3. The amendment revised TS 3.8.1, "AC Sources - Operating," to allow a 21-day completion time for an emergency diesel generator [Ref. 8.6].

6.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) as follows:

(i) The proposed change involves no significant hazards consideration.

As described in Section 4.2 above , the proposed change involves no significant hazards consideration.

(ii) There are no significant changes in the types or significant increase in the amounts of any effluents that may be released off-site.

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 20 of 24 The proposed change implements temporary TS requirements for the Unit 1 Emergency Power System and, as such, does not involve the installation of any new equipment or the modification of any equipment that may affect the types or amounts of effluents that may be released off-site. The proposed change will have no impact on normal plant releases and will not increase the predicted radiological consequences of accidents postulated in the UFSAR. There are no significant changes in the types or significant increase in the amounts of any effluents that may be released off-site.

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

The proposed change implements temporary TS requirements for the Unit 1 Emergency Power System to support replacement of RSST-C and associated cabling. The proposed TS change does not implement plant physical changes or result in plant operation in a configuration outside the plant safety analyses or design basis. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure associated with the proposed change.

Based on the above, Dominion Energy Virginia concludes that, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 CONCLUSION

The proposed change adds a footnote to TS 3.16 , "Emergency Power System" to allow a one-time extension of the Unit 1 AOT in TS 3.16 Action B.2 from 7 days to 21 days.

The design function of the Emergency Power System and the station's compliance with GDC 17 are not affected by the proposed change . Additionally, the proposed TS change does not physically alter plant equipment and does not affect the safety analyses.

Therefore, Dominion Energy Virginia concludes, based on the considerations discussed herein , that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations , and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

8.0 REFERENCES

8.1 UFSAR Figure 8.3-1, "Electric Power Distribution" 8.2 NUREG-0800, Standard Review Plan, Branch Technical Position (BTP) 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions"

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 21 of 24 8.3 NRG Reg. Guide 1.155, "Station Blackout," dated August 1988 8.4 NRG Reg. Guide 1.93, "Availability of Electric Power Sources", dated December 1974 8.5 Letter to Mr. Rafael Flores (Luminant Generation Company) from Balwant K.

Singal (USNRC) , dated September 18, 2013, "Comanche Peak Nuclear Power Plant, Units 1 and 2 - Issuance of Amendments Re: Revision to Technical Specification 3.8.1, 'AC Sources - OPERATING,' for Two 14-Day Completion Times for Offsite Circuits (TAC Nos. MOF405 and MF0406)" (ADAMS Accession No. ML13232A143) 8.6 Letter to Mr. Robert S. Bement (Arizona Public Service Company) from Siva P.

Lingam (USNRC), dated December 23 , 2016, "Palo Verde Nuclear Generating Station, Unit 3 - Issuance of Amendments Re: Revision to Technical Specification 3.8.1 , "AC [Alternating Current] Sources-Operating (Emergency Circumstances) (CAC No. MF8961)" (ADAMS Accession No. ML16358A676) 9.0 FIGURES 9.1 Existing Configuration 9.2 Temporary 21-day AOT Configuration 9.3 Surry Electric Power Distribution

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 22 of 24 CombusUon Combustion Gas Gas Church-Yadkin Turbines Turbines Chuckatuck Hopewell Winchester Hopewell SEPTA Suffolk Chickahominy rurbine 1 Turbine 2 la nd 5&6 3&4 L

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BUS6-BUS A RSST C RSST 8 RSST BUS D BUSf BUS F

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~Safety Bus 1J (EoG'\__

~ *** - Safety Bus iJ Figure 9 .1: Existing Configuration

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 23 of 24 Combu tion Combustion Gas Ga s Church-Winchester Hopewell SEPTA Suffolk Chickahominy Yadkin Turbines Turbines Chuckatuck Hopewell Turbine 1 Turbine 2 land 5 &6 3&4

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system Reserve ystem Reserve M 'n Transformer Transformer Transformer Tr ntfonn r 4

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~ Safety Bus 2J Figure 9.2 : Temporary 21 -day AOT Configuration

Serial No.17-435 Docket Nos. 50-280/281 Attachment 1 Page 24 of 24 I

Figure 9.3: Surry Electric Power Distribution

Serial No.17-435 Docket Nos. 50-280/281 Attachment 2 REGULATORY COMMITMENT

SUMMARY

Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Station Units 1 and 2

Serial No.17-435 Docket Nos. 50-280/28 1 Attachment 2 Page 1of1 REGULATORY COMMITMENT

SUMMARY

No. Commitment Due Date/Event The temporary 21-day AOT wi ll be used only once during During the time RSST-C 1 the fall 2018 Unit 2 refueling outage to complete the RSST- is out of service in the C and associated cabling rep lacement. Unit 2 outage, fall of 2018 Weather conditions will be monitored and preplanned During the time RSST-C 2 maintenance will not be scheduled if severe weather is out of service in the conditions are anticipated. Unit 2 outage , fall of 2018 The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading During the time RSST-C 3 unable to withstand a single contingency of line or is out of service in the generation outage) are expected during the temporary 21 - Unit 2 outage, fall of 2018 day AOT.

Component testing or maintenance of safety systems and important non-safety equipment in the offsite power systems During the time RSST-C 4 that can increase the likelihood of a plant transient (unit trip) is out of service in the or LOOP will be avoided. In addition, no discretionary Unit 2 outage, fall of 2018 switchyard maintenance will be performed.

TS required systems, subsystems , trains , components , and devices that depend on the remaining power sources will be During the time RSST-C verified to be operable and positive measures will be 5 is out of service in the provided to preclude subsequent testing or maintenance Unit 2 outage, fall of 2018 activities on these systems , subsystems, trains ,

components , and devices .

Operation or maintenance of plant equipment when its redundant equipment or train is out of service will be During the time RSST-C controlled in accordance with procedure OP-SU-601 ,

6 is out of service in the "Protected Equipment". The Unit 1 steam-driven Auxiliary Unit 2 outage, fall of 2018 Feedwater Pump will be controlled as "Protected Equipment" during the temporary 21-day AOT.

The status of the AAC diesel generator, EDGs , RSST-A and During the time RSST-C 7 RSST-B will be monitored once per shift. is out of service in the Unit 2 outage, fall of 2018

Serial No.17-435 Docket Nos. 50-280/281 Attachment 3 MARKED-UP TECHNICAL SPECIFICATIONS AND BASIS PAGES (Basis Changes are for NRC Information Only)

Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Station Units 1 and 2

05 a1 11 T. (Continued)

16. For the applicable UFSAR Chapter 14 Prior to operating above events, Surry 1 will re-analyze the 2546 MWt (98.4% RP).

transient consistent with VEPCO's NRG-approved reload design methodology in VEP-FRD-42, Rev. 2.1-A.

If NRG review is deemed necessary pursuant to the requirements of 10 CFR 50.59, the accident analyses will be submitted to the NRG for review prior to operation at the uprate power level. These commitments apply to the following Surry 1 UFSAR Chapter 14 DNBR analyses that were analyzed at 2546 MWt consistent with the Statistical DNBR Evaluation Methodology in VEP-NE-2-A:

Section 14.2.7 - Excessive Heat Removal due to Feedwater System Malfunctions (Full Power Feedwater Temperature Reduction case only);

Section 14.2.8 - Excessive Load Increase Incident;

Section 14.2.9 - Loss of Reactor Coolant Flow; and

Section 14.2.10 - Loss of External Electrical Load U. Deleted by Amendment No. 289 t

4. renewed license is effective as of the date of issuance and shall expire at midnight 25, 2032.

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by:

Samuel J. Collins, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix/\, Technical Specifications V. As discussed in the footnote to Technical Specification 3.16.B.2, the use of a temporary 21-day allowed outage time will permit Unit 1 to continue to operate for 21 days during the fall 2018 Unit 2 refueling outage to facilitate replacement of Reserve Station Service Transformer C and associated cabling (

Reference:

Letter Serial No.17-435, dated November 7, 2017.

Surry - Unit 1 Renewed License No. DPR-32 Amendment No. 289

05 a1 17 T. (Continued)

16. For the applicable UFSAR Chapter 14 Prior to operating above events, Surry 2 will re-analyze the 2546 MWt (98.4% RP).

transient consistent with VEPCO's NRG-approved reload design methodology in VEP-FRD-42, Rev. 2.1-A.

If NRG review is deemed necessary pursuant to the requirements of 10 CFR 50.59, the accident analyses will be submitted to the NRG for review prior to operation at the uprate power level. These commitments apply to the following Surry 2 UFSAR Chapter 14 DNBR analyses that were analyzed at 2546 MWt consistent with the Statistical DNBR Evaluation Methodology in VEP-NE-2-A:

Section 14.2. 7 - Excessive Heat Removal due to Feedwater System Malfunctions (Full Power Feedwater Temperature Reduction case only);

Section 14.2.8 - Excessive Load Increase Incident;

Section 14.2.9 - Loss of Reactor Coolant Flow; and

Section 14.2.10 - Loss of External Electrical Load U. Deleted by Amendment No. 289

4. T renewed license is effective as of the date of issuance and shall expire at midnight on J uary 29, 2033.

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by:

Samuel J. Collins, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A, chnical S ecifications V. As discussed in the footnote to Technical Specification Date of Issuance: March 20, 3.16.B.2, the use of a temporary 21-day allowed outage time will permit Unit 1 to continue to operate for 21 days during the fall 2018 Unit 2 refueling outage to facilitate replacement of Reserve Station Service Transformer C and associated cabling (

Reference:

Letter Serial No.17-435, dated November 7, 2017.

Surry - Unit 2 Renewed License No. DPR-37 Amendment No. 289

TS 3.16-1 No change on this page - included for information only. 06-07-99 3.16 EMERGENCY POWER SYSTEM Applicability Applies to the availability of electrical power for safe operation of the station during an emergency.

Objective To define those conditions of electrical power availability necessary to shutdown the reactor safely, and provide for the continuing availability of Engineered Safeguards when normal power is not available.

Specification A. A reactor shall not be made critical nor shall a unit be operated such that the reactor coolant system pressure and temperature exceed 450 psig and 350°F, respectively, without:

1. Two diesel generators (the unit diesel generator and the shared backup diesel generator) OPERABLE with each generator's day tank having at least 290 gallons of fuel and with a minimum on-site supply of 35,000 gal of fuel available.

2. Two 4,160V emergency buses energized.

3. Four 480V emergency buses energized.

Amendment Nos. 220 and 220

TS 3.1~2 No change on this page - included for information only . 04-05-05

4. Two physically independent circuits from the o:ffsite transmission network to energize the 4, 160V and 480V emergency buses. One of these sources must be immediately available (i.e. primary source) and the other must be capable of being made available within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (i.e. dependable alternate source).

5. Two OPERABLE flow paths for providing fuel to each diesel generator.

6. Two station batteries, two chargers, and the DC distribution systems OPERABLE.

7. Emergency diesel generator battery, charger and the DC control circuitry OPERABLE for the unit diesel generator and for the shared back-up diesel generator.

B. During POWER OPERATION or the return to power from HOT SHUTDOWN, the requirements of specification 3.16-A may be modified by one of the following:

La. With either unit's dedicated diesel generator or shared backup diesel generator unavailable or inoperable:

1. Verify the operability of two physically independent offsite AC circuits within one hour and at least once per eight hours thereafter.

2. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , determine that the OPERABLE diesel generator is not inoperable due to common cause failure or demonstrate the operability of the remaining OPERABLE diesel generator by performing Surveillance Requirement 4.6.A.1.a For the purpose of operability testing, the second diesel generator may be inoperable for a total of two hours per test provided the two offsite AC circuits have been verified OPERABLE prior to testing.

3. lf this diesel generator is not returned to an OPERABLE status within 7 days, the reactor shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

l.b. One diesel fuel oil flow path may be "inoperable" for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the other flow path is proven OPERABLE. If after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the inoperable flow path cannot be returned to service for reasons other than buried fuel oil storage tank inspection and related repair, the diesel shall be considered "inoperable."

When the emergency diesel generator battery, charger or DC control circuitry is inoperable, the diesel shall be considered "inoperable."

Amendment Nos. 241and240

TS 3.16-3 07 22 09

2. If a primary source is not available, the unit may be operated for seven (7) days provided the dependable alternate source can be OPERABLE within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . If specification A-4 is ~nfflsfied within seven (7) days, the unit shall be brought to COLD SHUTDOWNC2J

3. One battery may be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the other battery and battery chargers remain OPERABLE with one battery charger carrying the DC load of the failed battery's supply system. If the battery is not returned to OPERABLE status within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, the reactor shall be placed in HOT SHUTDOWN. If the battery is not restored to OPERABLE status within an additional 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the reactor shall be placed in COLD SHUTDOWN.

4. One buried fuel oil storage tank may be inoperable for 7 days for tank inspection and related repair, provided the following actions are taken:

a. prior to removing the tank from service, verify that 50,000 gallons of replacement fuel oil is available offsite and transportation is available to deliver that volume of fuel oil within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , and

b. prior to removing the tank from service and at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , verify that the remaining buried fuel oil storage tank contains ~ 17 ,500 gallons, and

c. prior to removing the tank from service and at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , verify that the above ground fuel oil storage tank contains ~ 50,000 gallons.

If these conditions are not satisfied or if the buried fuel oil storage tank is not returned to OPERABLE status within 7 days, both units shall be placed in HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

C. The continuous running electrical load supplied by an emergency diesel generator shall be limited to 2750 KW.

Basis The Emergency Power System is an on-site, independent, automatically starting power source. It supplies power to vital unit auxiliaries if a normal power source is not available. The Emergency Power System consists of three diesel generators for two units. The Unit 1 diesel generator and the Unit 2 diesel generator are dedicated to emergency buses lH and 2H, respectively. A third diesel generator is provided as a "swing diesel" and is shared by Units 1 and 2. Upon receipt of a safety injection signal on a unit, the shared diesel generator automatically aligns to either emergency bus 1J (Unit 1) or 2J (Unit 2) as a backup power supply for the accident unit. The shared diesel is configured to preferentially load to the Unit 2 emergency bus on a loss of offsite power without a safety injection signal. The Unit 1 and Unit 2 diesel generators also supply power for certain common or shared plant systems/components. The diesel generators have a cumulative 2,000 hour0 days 0 hours 0 weeks 0 months rating of 2750 KW. The actual loads are verified by engineering calculation to remain below the 2750 kw limit.

Amendment Nos. BftSeS'

Insert following as footnote to TS 3.16.B.2 on page TS 3.16-3:

(*) To facilitate the replacement of the Reserve Station Service Transformer C and associated cabling during the fall 2018 Unit 2 refueling outage, the use of a temporary, one-time, 21-day allowed outage time (AOT) is permitted for the unavailability of a primary source. Prior to entry into and during the 21-day AOT, the following actions shall be taken :

Within 30 days prior to entering the temporary 21-day AOT, functionality of the Alternate AC (AAC) System (i.e., the supplemental power source) shall be verified .

During the 21-day AOT, the functionality of the AAC System shall be checked once per shift. If the AAC System becomes non-functional at any time during the 21 -day AOT, it shall be restored to functional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the unit shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

TS 3.16-7 04 05 05 TS action statement 3.16.B.1.a.2 provides an allowance to avoid unnecessary testing of an OPERABLE EDG(s). If it can be determined that the cause of an inoperable EDG does not exist on the OPERABLE EDG(s), operability testing does not have to be performed. If the cause of the inoperability exists on the other EDG(s), then the other EDG(s) would be declared inoperable upon discovery, and the applicable required action(s) would be entered. Once the failure is repaired, the common cause failure no longer exists and the operability testing requirement for the OPERABLE EDG(s) is satisfied. If the cause of the initial inoperable EDG cannot be confirmed not to exist on the remaining EDG(s),

performance of the operability test within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provides assurance of continued operability of those EDG(s).

In the event the inoperable EDG is restored to OPERABLE status prior to completing the operability testing requirement for the OPERABLE EDG(s), the corrective action program will continue to evaluate the common cause possibility, including the other unit's EDG or the shared EDG. This continued evaluation, however, is no longer under the 24-hour constraint imposed by the action statement.

According to Generic Letter 84-15 (Ref. 6), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that the OPERABLE EDG(s) is not affected by the same problem as the inoperable EDG.

References (1) UFSAR Section 8.5 Emergency Power System (2) UFSAR Section 9.3 Residual Heat Removal System (3) UFSAR Section 9.4 Component Cooling System (4) UFSAR Section 10.3.2 Auxiliary Steam System (5) UFSAR Section 10.3.5 Condensate and Feedwater System (6) Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," dated July 2, 1984 Amendment Nos. 2:41 ttHcl 2:40

Insert following TS 3.16 Basis on page TS 3.16-7:

Reserve Station Service Transformer (RSST) C is the primary offsite power source for the 1 H and 2J Emergency Buses via transfer bus F. To facilitate the replacement of RSST-C and associated cabling during the fall 2018 Unit 2 refueling outage , Technical Specification 3.16.8.2 is modified by a footnote permitting the use of a temporary, one time, 21-day allowed outage time (AOT) . The 21-day AOT will permit Unit 1 to continue to operate for 21 days. While RSST-C is unavailable during replacement, transfer bus F will be powered from the dependable alternate source (i. e., backfeed through the Unit 2 Main Step-up Transformer/2C Station Service Transformer). The backfeed power supply will allow transfer bus F to perform its normal function while RSST-C is being replaced . Prior to entry into and during the 21-day AOT, the following actions shall be taken :

1. Within 30 days prior to entering the temporary 21 -day AOT, functionality of the Alternate AC (AAC) System (i.e ., the supplemental power source) shall be verified .

2. During the 21-day AOT, the functionality of the AAC System shall be checked once per shift. If the AAC System becomes non-functional at any time during the 21-day AOT, it shall be restored to functional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the unit shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The verification of functionality of the AAC System prior to entering the temporary 21-day AOT will be based on the previous satisfactory quarterly test. The once per shift functionality check will be performed during shiftly operator rounds.

In addition to verifying and checking functionality of the AAC System prior to and during the temporary 21-day AOT, the following actions will be taken :

Weather conditions will be monitored and preplanned maintenance will not be scheduled if severe weather conditions are anticipated.

The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the temporary 21-day AOT.

Component testing or maintenance of safety systems and important non-safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided . In add ition , no discretionary switchyard maintenance will be performed .

TS required systems, subsystems , trains, components , and devices that depend on the remaining power sources will be verified to be operable and positive measures will be provided to preclude subsequent testing or maintenance activities on these systems, subsystems, trains , components , and devices .

Operation or maintenance of plant equipment when its redundant equipment or train is out of service will be control led in accordance with procedure OP-SU-601 , "Protected Equipment". The Unit 1 steam-driven Auxiliary Feedwater Pump will be controlled as "Protected Equipment" during the temporary 21-day AOT.

The status of the AAC diesel generator, EDGs, RSST-A and RSST-B will be monitored once per shift.

Serial No.17-435 Docket Nos. 50-280/281 Attachment 4 PROPOSED TECHNICAL SPECIFICATIONS AND BASIS PAGES (Basis Changes are for NRC Information Only)

Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Station Units 1 and 2

T. (Continued)

16. For the applicable UFSAR Chapter 14 Prior to operating above events, Surry 1 will re-analyze the 2546 MWt (98.4% RP).

transient consistent with VEPCO's N RC-approved reload design methodology in VEP-FRD-42, Rev. 2.1-A.

If N RC review is deemed necessary pursuant to the requirements of 10 CFR 50.59 , the accident analyses will be submitted to the NRC for review prior to operation at the uprate power level. These commitments apply to the following Surry 1 UFSAR Chapter 14 DNBR analyses that were analyzed at 2546 MWt consistent with the Statistical DNBR Evaluation Methodology in VEP-NE-2-A:

Section 14.2.7 - Excessive Heat Removal due to Feedwater System Malfunctions (Full Power Feedwater Temperature Reduction case only);

Section 14.2.8 - Excessive Load Increase Incident;

Section 14.2.9 - Loss of Reactor Coolant Flow; and

Section 14.2.10 - Loss of External Electrical Load U. Deleted by Amendment No. 289 V. As discussed in the footnote to Technical Specification 3.16 B.2, the use of a temporary 21-day allowed outage time will permit Unit 1 to continue to operate for 21 days during the fall 2018 Unit 2 refueling outage to facilitate replacement of Reserve Station Service Transformer C and associated cabling (

Reference:

Letter Serial No.17-435, dated November 7, 2017) .

4. Th is renewed license is effective as of the date of issuance and shall expire at midnight on May 25 , 2032 .

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by:

Samuel J . Collins, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A, Technical Specifications Date of Issuance: March 20, 2003 Surry - Unit 1 Renewed License No. DPR-32 Amendment No.

T. (Continued))

16. For the applicable UFSAR Chapter 14 Prior to operating above events, Surry 2 will re-analyze the 2546 MWt (98.4% RP).

transient consistent with VEPCO's NRG-approved reload design methodology in VEP-FRD-42, Rev. 2.1-A.

If NRC review is deemed necessary pursuant to the requirements of 10 CFR 50.59, the accident analyses will be submitted to the NRC for review prior to operation at the uprate power level. These commitments apply to the following Surry 2 UFSAR Chapter 14 DNBR analyses that were analyzed at 2546 MWt consistent with the Statistical DNBR Evaluation Methodology in VEP-NE-2-A:

Section 14.2.7 - Excessive Heat Removal due to Feedwater System Malfunctions (Full Power Feedwater Temperature Reduction case only);

Section 14.2.8 - Excessive Load Increase Incident;

Section 14.2.9 - Loss of Reactor Coolant Flow; and

Section 14.2.10 - Loss of External Electrical Load U. Deleted by Amendment No . 289 V. As discussed in the footnote to Technical Specification 3.16 B.2, the use of a temporary 21-day allowed outage time will permit Unit 1 to continue to operate for 21 days during the fall 2018 Unit 2 refueling outage to facilitate replacement of Reserve Station Service Transformer C and associated cabling (

Reference:

Letter Serial No.17-435, dated November 7, 2017).

4. This renewed license is effective as of the date of issuance and shall expire at midnight on January 29, 2033.

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by:

Samuel J. Coll ins, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A, Technical Specifications Date of Issuance: March 20, 2003 Surry - Unit 2 Renewed License No. DPR-37 Amendment No.

TS 3.16-3

2. If a primary source is not available, the unit may be operated for seven (7) days provided the dependable alternate source can be OPERABLE within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . If specification A-4 is not satisfied within seven (7) days, the unit shall be brought to COLD SHUTDOWN.(*)

3. One battery may be inoperable for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided the other battery and battery chargers remain OPERABLE with one battery charger carrying the DC load of the failed battery's supply system. If the battery is not returned to OPERABLE status within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, the reactor shall be placed in HOT SHUTDOWN. If the battery is not restored to OPERABLE status within an additional 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the reactor shall be placed in COLD SHUTDOWN.

4. One buried fuel oil storage tank may be inoperable for 7 days for tank inspection and related repair, provided the following actions are taken:

a. prior to removing the tank from service, verify that 50,000 gallons of replacement fuel oil is available offsite and transportation is available to deliver that volume of fuel oil within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , and

b. prior to removing the tank from service and at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , verify that the remaining buried fuel oil storage tank contains ~ 17 ,500 gallons, and

c. prior to removing the tank from service and at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , verify that the above ground fuel oil storage tank contains ~ 50,000 gallons.

(*) To facilitate the replacement of the Reserve Station Service Transformer C and associated cabling during the fall 2018 Unit 2 refueling outage, the use of a temporary, one-time, 21-day allowed outage time (AOT) is permitted for the unavailability of a primary source. Prior to entry into and during the 21-day AOT, the following actions shall be taken:

Within 30 days prior to entering the temporary 21-day AOT, functionality of the Alternate AC (AAC) System, (i.e., the supplemental power source) shall be verified.

During the 21-day AOT, the functionality of the AAC System shall be checked once per shift. If the AAC System becomes non-functional at any time during the 21-day AOT, it shall be restored to functional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the unit shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Amendment Nos.

TS 3.16-3a If these conditions are not satisfied or if the buried fuel oil storage tank is not returned to OPERABLE status within 7 days, both units shall be placed in HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

C. The continuous running electrical load supplied by an emergency diesel generator shall be limited to 2750 KW.

Basis The Emergency Power System is an on-site, independent, automatically starting power source. It supplies power to vital unit auxiliaries if a normal power source is not available. The Emergency Power System consists of three diesel generators for two units. The Unit 1 diesel generator and the Unit 2 diesel generator are dedicated to emergency buses lH and 2H, respectively. A third diesel generator is provided as a "swing diesel" and is shared by Units 1 and 2. Upon receipt of a safety injection signal on a unit, the shared diesel generator automatically aligns to either emergency bus 1J (Unit 1) or 2J (Unit 2) as a backup power supply for the accident unit. The shared diesel is configured to preferentially load to the Unit 2 emergency bus on a loss of offsite power without a safety injection signal. The Unit 1 and Unit 2 diesel generators also supply power for certain common or shared plant systems/components. The diesel generators have a cumulative 2,000 hour0 days 0 hours 0 weeks 0 months rating of 2750 KW. The actual loads are verified by engineering calculation to remain below the 2750 kw limit.

Amendment Nos. Bases

TS 3.16-7 TS action statement 3. 16.B. l .a.2 provides an allowance to avoid unnecessary testing of an OPERABLE EDG(s). If it can be determined that the cause of an inoperable EDG does not exist on the OPERABLE EDG(s), operability testing does not have to be performed. If the cause of the inoperability exists on the other EDG(s), then the other EDG(s) would be declared inoperable up on discovery, and the app licable required actio n(s) would be entered. Once the fai lure is repaired, the common cause failure no longer exists and the operability testing requirement for the OPERABLE EDG(s) is satisfied. If the cause of the initial inoperable EDG cann ot be confirmed not to exist on the re maining EDG(s) ,

performance of the operability test within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provides assurance of co ntinued operability of those EDG(s).

In the event the inoperable EDG is restored to OPERABLE status prior to comp leting the operability testing requirement for the OPERABLE EDG(s), the corrective action program wi ll continue to evaluate the common cause possibility, including the other unit's EDG or the shared EDG. This continued evalu atio n, however, is no longer under the 24-hour constraint imposed by the action statement.

According to Generic Letter 84-15 (Ref. 6), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that the OPERABLE EDG(s) is not affected by the same problem as the inoperable EDG.

Reserve Station Service Transformer (RSST) C is the primary offsite power source for the lH and 2J Emergency Buses via transfer bus F. To facilitate the replacement of RSST-C and as ociated cab lin g during the fall 2018 U nit 2 refueling outage, Technical Specification 3. 16.B.2 is modified by a footnote permitting the use of a temporary, one time, 21-day allowed outage time (AOT). The 21-day AOT wi ll permit Unit 1 to continue to operate for 21 days. While RSST-C is unavailable during rep lacement, transfer bus F wi ll be powered fro m the dependable alternate source (i.e, backfeed through the Unit 2 Main Step-up Transformer/2C Station Services Transformer). The backfeed power supply wi ll allow transfer bus F to perform its normal function while RSST-C is being replaced.

Prior to entry into the 21-day AOT, the following actions shall be taken:

1. Within 30 days prior to entering the temporary 21-day AOT, functionality of the Alternate AC (AAC) System (i .e., the supplemental power source) shall be verified.

2. During the 21-day AOT, the functionality of the AAC System shall be checked once per shift. If the AAC System becomes non-functional at any time during the 21-day AOT, it shall be restored to functional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the unit shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the fo ll owi ng 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Amendment Nos.

TS 3.16-7a The verification of functionality of the AAC System prior to entering the temporary 21-day AOT wi II be based on the previous satisfactory quarterly test. The once per shift functionality check will be performed durin g shiftly operator rounds.

In addition to verifying and checking functionality of the AAC System prior to and during the temporary 21-day AOT, the following actions will also be taken:

Weather conditions will be monitored and preplanned maintenance will not be scheduled if severe weather conditions are anticipated.

The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the temporary 21-day AOT.

Component testing or maintenance of safety systems and important non-safety equipment in the offsite power systems that can increase the likelihood of a plant transient (un it trip) or LOOP will be avoided. In addition, no discretionary switchyar maintenance will be perfom1ed .

TS required systems, subsystems, trains, components, and devices that depend on the remaining power sources will be verified to be operable and positive measures will be provided to preclude subsequent testin g or maintenance activities on these systems, subsystems, trains, components, and devices.

Operation or maintenance of plant equipment when its redundant equipment or train is out of service will be controlled in accordance with procedure OP-SU-601, "Protected Equipment." The Unit l steam-driven Auxiliary Feedwater Pump will be controlled as "Protected Equipment" during the temporary 21-day AOT.

The status of the AAC diesel generator, EDGs, RSST-A and RSST-B will be monitored once per shift.

Amendment Nos.

ML17317A464

Contents

Text

SUMMARY

Reference:

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

8.0 REFERENCES

SUMMARY

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ML17317A464

Text

SUMMARY

Reference:

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

8.0 REFERENCES

SUMMARY

SUMMARY

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Reference:

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