ML18143B684
| ML18143B684 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/11/1985 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8510310022 | |
| Download: ML18143B684 (5) | |
Text
- '-.
Docket Nos. 50-280 and 50-281 Mr. W. L. Stewart October 11, Vice President - Nuclear Operations Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261
Dear Mr. Stewart:
1985 e
D lS.TR-IBUT-LOJ:J JJia.cke.t,...F-Ue._:i NRC PDR Local PDR ORB#l Reading File H. Thompson OELD
SUBJECT:
PROPOSED TECHNICAL SPECIFICATION CHANGES FOR SNUBBER SURVEILLANCE REQUIREMENTS (VEPCO SERIAL NO.85-556)
E. Jordan B. Grimes J. Partlow C. Parrish ACRS (10)
Gray Fi le The staff has reviewed the proposed Technical Specification changes for snubber surveillance requirements as provided in the VEPCO letter dated August 9, 1985.
In using the Standard Technical Specifications as a reference and model, a revision to the amendment request, additional information or justification as stated in the enclosure to this letter is necessary for us to complete our review.
These items and other comments were discussed with Joe Hegner and Harry Miller, et.al, of your staff in a telephone conversation on September 18, 1985.
We request that you provide this information within 30 days or provide us with a schedule for doing so.
In addition, we wish to call to your attention that the ASME O&M-4
- standard, 11 Examination and Performance Testing of Nuclear Power Plant Dynamic Restraints (SNUBBERs),
11 has not been approved or endorsed by the Commission, as it has not yet been published.
Although individual committee members employed by the NRC may concur with the draft of the proposed standard, final determination of the standard will not occur prior to the staff's review of the published document.
The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, 0MB clearance is not required under P.L.96-511.
Enclosure:
As stated cc w/enclosure: ~
See next page r-t;:-
- ORB#l: DL OR '#1: bL CParrish:kb TChan 10/ 9 /85 10/ i /85
- See next page for concurrence Sincerely,
/s/SVarga Steven A. Varga, Chief Operating Reactors Branch #1 Division of Licensing
(
8510310022 851011 *1 PDR ADOCK 05000280 p
Docket Nos. 50-280 and 50-281 Mr. W. L. Stewart Vice President - Nuclear Operations Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261
Dear Mr. Stewart:
e DI STR IBUTI ON Docket File NRC PDR Local PDR ORB#l Reading File H. Thompson OELD
SUBJECT:
PROPOSED TECHNICAL SPECIFICATION CHANGES FOR SNUBBER SURVEILLANCE REQUIREMENTS (VEPCO SERIAL NO.85-556)
E. Jordan B. Grimes J. Partlow C. Parrish ACRS (10)
Gray Fi le The staff has reviewed the proposed Technical Specification changes for snubber surveillance requirements as provided in the VEPCO letter dated August 9, 1985.
In using the Standard Technical Specifications as a reference and model, a revision to the amendment request, additional information or justification as stated in the enclosure to this letter is necessary for us to complete our review.
These items and other comments were discussed with Joe Hegner and Harry Miller, et.al, of your staff in a telephone conversation on September 18, 1985.
We request that you provide this information within 30 days or provide us with a schedule for doing so.
In addition, we wish to call to your attention that the ASME O&M-4
- standard, 11 Examination and Performance Testing of Nuclear Power Plant Dynamic Restraints (SNUBBERs),
11 has not been approved or endorsed by the Commission, as it has not yet been published.
Although individual committee members employed by the NRC may concur with the draft of the proposed standard, final determination, of the standard will not occur prior to the staff 1s review of the published document.
The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, 0MB clearance is not required under P.L.96-511.
Enclosure:
As stated cc w/enclosure:
See next page ORB#l :DL
~ 0 CParrish:kb \\ T 10/ C\\/85 1
Sincerely, Steven A. Varga, Chief Operating Reactors Branch #1 Division of Licensing BC/ORB#l: DL SVarga 10/ /85
... ~
e Mr. W. L. Stewart Virginia Electric and Power Company cc:
Mr. Michael W. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virginia 23213 Mr. Robert F. Saunders, Manager Surry Power Station Post Office Box 315 Surry, Virginia 23883 Donald J. Burke, Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission Post Office Box 166, Route 1 Surry, Virginia 23883 Mr. Sherlock Holmes, Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 W. T. Lough Virginia Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23209
~:Mr. J. H. Ferguson Executive Vice President - Power Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 James B. Kenley, M.D., Commissioner Department of Health 109 Governor Street Richmond, Virginia 23219 Surry Power Station Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219
REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATION CHANGES re:
SNUBBER SURVEILLANCE REQUIREMENTS Enclosure
- 1. Applicability Section of Proposed Technical Specifications (TS)-3.20 and 4.17
- 2.
- 3.
Provide clarification to indicate whether the only snubbers which can be excluded from the TS requirements are those installed on non-safety related systems and then only if their failure or failure of the system on which they are installed would have no adverse affect on any safety-related system.
Proposed TS Section 3.20.A Contrary to requirements of Section 3.7.9 of the Standard Technical Specification attached to Generic Letter 84-13, snubbers on systems required to be operable during cold shutdown and refueling are not required (according to proposed TS 3.20.A) to be operable during these conditions. Provide a justification.
Proposed TS Section 4.17.* A - Inspection Groups The criteria to be used for subdividing accessible and inaccessible snubber groups into subgroups need to be specified. Since the ASME Standard, O&M-4, has not yet been published, and since _this document has not yet been approved and accepted by NRC, the TS must specify definite criteria used to select the subgroups.
The criteria selected should be justified based on past testing and inspection results and the manufacturer's recommendation.
- 4.
Proposed TS Section 4.17.D.6 Functional testing of an additional 10% of the snubbers in the subgroup for each snubber failure within the subgroup does not meet the require-ments of O&M-4 or the Standard Technical Specifications.
The draft of O&M-4 specifies that for each snubber that does not meet the functional test acceptance criteria, an additional *sample of at least 1/2 the size of the initial sample lot shall be selected for functional testing. Section 4.7.9.C of the Standard Technical*
Specifications requires that an additional 10% of the snubbers be functionally tested for each functional test failure.
This paragraph needs to be revised to discuss how the requirements of Section 4.7.9.C of the Standard Technical Specifications or O&M-4 will be met.
Enclosure 5.
Proposed TS Sections 4.17.E.1.a and 4.17.F.1.b The word "Activity" appears to have been incorrectly used in the place of "Activation." Please revise if appropriate.
- 6. Third Paragraph of BASIS of TS 4.17 Provide additional justification for considering some snubbers inside containment as accessible during power operation. This justification should address ALARA concerns, as well as other safety concerns regarding exposure of snubber inspection personnel to the additional radiation hazards, high heat and humidity, and the subatmospheric containment environments. Clarify how snubber reliability will be improved by reclassifying some snubbers currently considered inaccessible as accessible.
- 7. Safety Evaluation for SPS Technical Specification Change There are two statements in the Safety Evaluation which requires clarification. These are as follows:
- a. "Second line of second paragraph " *** within the broad family of mechanical snubbers.
11 Since all mechanical snubbers installed at Surry were manufactured by PSA~ and the various sizes of PSA snubbers are essentially similar in design, clarification of this statement is necessary.
- b.
Fifth line of second paragraph - Discussion regarding IE Bulletin 81-01 inspection criteria needs clarification or revision.
IE Bulletin 81-01 contained two sets of inspection criteria. One set of criteria was specified for INC snubbers and was based on numerous problems identified with these type snubbers. The