ML18139A427
| ML18139A427 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/08/1980 |
| From: | Spencer W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 591, IEB-79-14, NUDOCS 8007110390 | |
| Download: ML18139A427 (3) | |
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VIRGINIA ELECT~IO.A.Nn:PoWER c*oMPANY RIOHMOND, VIRGINIA 23261 July* 8,- 1980 Mr. James* p-~ o**Rei11y~ Director-.
Office of.Inspection & Enforcement U *. s.. Nuclear.- R~gu.l ~tory Commi 5Si on, Serial No. 591
- PSE~1CS/ CMRjr :mac: wanQ.
Regioh II 101 Mtri etta Street, Suite 3100 _.
Atlanta, _G~orgia: 303~3. *
- Docket No. 50-281**
- Licen~e No. OPR-37 *
Dear Mr. 0 1 RP.illy_:
I. L-BULLETIN 79~"i4 sv*srEMS ours m( CONTAINMENT *
- SURRY POWER STATION *UNIT 2
.The *purpose* of this* letter is to identify those -actions *which we propose to t~ke with regard to I.E. *Bulletin 79-!4 ~pon-start-up of Sur~y Po0er
- Station Unit 2.
- Ou~ propcisal is predi~ated on pre~ious pr~cedents _and_
corrmi tments $et *t: or: St,rry c1.11cl _o_ther pcitier.s~ations 1:1nder simi 1,ar circumstances, and**we therefore consi_der-our proposal to be consistent with our mutual concern-for safe operation** of the' unit *. *
~
.
- Our request for start-up of Unit 2-in Ollr letter *of..February 26,. i980 c*
.(Vepco Serial No. Jit4) i;ieli'neate(-J'"Hhat* \\*mrk* 1*mu1d bP. completed prior tq st a.rt-up.. The work that would not be. comp l et.ect prior to start'-up
- was *._**
- identifi_ed* as support analysis and.modifications on I.E.Bulletin 79-14. *.
systems outside con~ainment.
- The--1-ine*s for t'hese systems are identified on the Surry Unit 2 Q,!\\ Category I,Pipe* Line:Table. Analys*is and modification~
will continue*on these systems ba.sed on the following logic:
- 1.
. A screening. proces~ wi 11 1-Je* u_sed for Technical Specificati 0~ systems to identify si gnif1can~1y ov~rst.ressed supports, for. which immediate action,_.,; n be t?..ken.
- The scre~riing process will *invoive two categ~ries of* supports:
- a.* _The first category consists of those'modificat1on*Jiackages which
. Vepco has rec~ived for the id~ntifie~ systems outside the
- containment up to th':! time.of start-up.* The screening process for these supports'will be completed within 30 days from the start-up d~te.
- b.
Those modification packages wh1ch Ve~c9 receives after start~up
. is the second category.
The screening pro~ess for this category of mod~fication packages will in all cases take place within 30 1
days from the receipt of the modification packages fr~m Vepco 1s(\\o~\\
- Architect-Engineers.
~-SI"[)
800,110 31:ro.
- r e
Mr. James P. O'Reilly Page 2
?.
A significantly overstresse~ support is defined to he one t~at fails to have a Factor of Safety of rtt least? with respect to ultimate capacity for the Dcsiqn Basis Earthaua~e lofirl case and also exceeds the criteria in Sutse~tion NF of AS~E III, Appendix F, Rul~s for Evaluation of Faulted Conditions.
- 3.
For supports that a.re significantly overstresserl as *defined by the criteiia in item*2 above, the applicable plant Techrical
- Spec1fic~t1~ns will be invoked to determine operahility and reports will be submitted as ~equired.
- 4.
Only.supports that are sigriificantly overstressed, as defined above,
- will be drs1gnated RS nonconform~nces.
- 5.
A11 modification packages for supports will he issu~rl by Vepco's
-Architect-Engineers i*1ithin 90 r.la.ys of the tfote of st1rt up.
At the conclusion of this 90 day period, Vepco will provide a completion date for instal1?1tfon of all remaining modifications.
The only_ exceptions to this logic *<1nd schedule are portions of the service
- ,-niter system* corrtaining fiber glass pip"lng identifi~~d in our letter of. Ma.rch 17, 1980 (Serial No. 1S'5).
Your approval for a separate schedule or: this piping ~as granted in Mr. Charles E. Murp~y's l~tter of May ?9, 1980 (RII:RMC S0-280).
The completion of analysis of the remaining* syitem~ outside the*
contain~f'nt for I.E. Bulletin 7S-14 while the unit is-operational represents a significantly rP.duced risk to the health and S?'fety of. the public.
Our conclusions are bn.sed on the follov.Jing observatfons rP.garding this approach:
- l.
All systems \\\\/hich 1t1ere originally dynamical.ly analyzed *as a. re5ult of
- the March 13; 1079 Order to Show Caus<?. h.:tve riow been reanalyzed, hoth inside and outside the containmentt *anrl re~ulting modifications have been ir.stalled, Completion of this reana1_ysis assures thctt the plant can attain a hot standby condition for all operating and design conditions.
Tl1e s:,ow C:1use 0-rder generally a.ffected piping gre2.ter than 6 11 in diameter.
. 2."
The I.E. Bulletin 79-1.4 systems for which reanalysis is continuing are outside containment and are accessible for all norm~l operatin~
conditi6ns. This Will expedite installation for required modifications (nonconformances) and facilitate continued installation of other supports.
- 3.
All ne1:1 supports and modified supports due to pipe stress reanal.vsis for I.E.Bulletin 79-14 on Technical Specification systems outside conta.inment will already he completed prior to start-up.
- 4.
The I.E. Bulletin 79:-14 systems are generally 2 J./2 11 to n 11 dirun~ter piping.
These systems are of less safet.v significance than t!ie Show Cause systems and therefore c:m be treated with a grnerally reduced severity level.
e Mr. James P. O'Reilly Page 3 We beli0ve our approach to dotermining those supports with significantly overstressed conditions is in conformance wit~ the criteria suggested in I.E.
This general approach was also follry~~d for S~ow Cause systems w'1"lle analyses continued on Surry power Station Unit 1 as directer! by the NRC Order of August??, 1979.
We also understand that this approach was also followed under similar circumstances other utilities. The precedents are numerous, and t!1e reRsoning presents a sound, responsible position tnward continued safe operation of the unit with no significant risk to the health and safety of the public.
In the past year and a half, Vepco has undertaken and completed a very.
extAnsive reanalysis effort for the Surry Power Station. This effort has resulted in an increased confidence level of our piping systems to perform their intendP.-c functions.
The only arPa r9m,ining for compl2ticn is a. portion*
of the I.E.Bulletin 79-14 systems outside the containment~ for* n._ smaller scope and reduced significarice from the original scope of reanalyzing all piping systems 2 1/2 11 diameter and greRter for both ins*ide 3.nd o*utside the containment.
The approach off~red herein has been used by Vepco and ot~ers to complete their analysis and is expected to be satisfactory once aga*in.
Please cont2ct us if there are outstanding questions on our proposal. We respectfully request confirmation as soon a.s possible as Unit 2 is presently sclv~duled for commercial operation at the end of July.
Very
\\iJ. C. Soer.cer Vice President-* Power Station Engineering and Construction Services cc: *Mr. Victor Stello, Director ~
Office of Inspection and Enforc~ment Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation