ML18149A144

Application for Amends to Licenses DPR-32 & DPR-37,revising Tech Specs to Add License Condition Authorizing Rev to Reactor Coolant Pump & Steam Generator Support Design to Mitigate Pipe Rupture Events

ML18149A144
Person / Time
Site:	Surry
Issue date:	04/30/1986
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Rubenstein L Office of Nuclear Reactor Regulation
Shared Package
ML18149A145	List: ML18149A144 ML18149A146
References
86-245, TAC-59821, TAC-59822, NUDOCS 8605050257
Download: ML18149A144 (4)

Text

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.. VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PRESIDENT April 30, 1986 Nucx.EAR OPERATIONS Mr. Harold R. Denton, Director Serial No.86-245 Office of Nuclear Reactor Regulation NO/JDH/acm Attn: Mr. Lester S. Rubenstein, Director Docket Nos. 50-280 PWR Project Directorate No. 2 50-281 Division of PWR Licensing-A License Nos. DPR-32 U.S. Nuclear Regulatory Commission DP.R-37 Washington, D.C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT NOS. 1 AND 2 PROPOSED LICENSE AMENDMENT - GDC 4 Pursuant to 10 CFR 50.90, the Virginia Electric and Power Company requests an amendment, in the form of a license condition, to Operating License Nos. DPR-32 and DPR-37 for Surry Unit Nos. 1 and 2. Proposed wording for the license condition is provided in Attachment 1. Our discussion of the proposed license condition is provided in Attachment 2.

The proposed amendment would add a license condition stating that the design of the reactor coolant pump and steam generator supports may be revised in accordance with our submittals dated November 5, 1985 (Serial No.85-136), December 3, 1985 (Serial No. 85-136A), and January 14, 1986 (Serial No. 85-136C). This change would permit 18 large-bore snubbers installed solely to mitigate the effects of pipe rupture events to be removed from each unit's primary loop.

This change was originally requested by exemption in our letter dated November 5, 1985 (Serial No.85-136). As stated in that and subsequent correspondence, it has been, and continues to be our intent to take advantage of this revision during the 1986 Surry refueling outages by permanently removing certain snubbers required solely to mitigate the dynamic effects of a reactor coolant system pipe rupture event. Surry 1 is currently scheduled to shutdown May 9, 1986 for a 48 day refueling outage. Surry 2 is currently scheduled to shutdown October 10, 1986, for a 58 day refueling outage.

Our original exemption request was in accordance with NRC guidance provided in Generic Letter 84-04,

• Safety Evaluation of Westinghouse Topical Reports Dealing With Elimination of Postulated Pipe Breaks in PWR Primary Main Loops, dated February 1, 1984. Subsequently, we submitted additional information on December 3, 1985 (Serial No. 85-136A), and

e e VIRGINIA. ELECTRIC AND POWER COMPANY TO Mr. Harold R. Denton January 14, 1986 (Serial No. 85-136C). In support of this request, we also met with you on December 19, 1985 to assure that our position on the various issues identified in Generic Letter 84-04 was well understood, to identify and attempt to resolve any new areas of concern, and to confirm the schedules necessary to support the 1986 Surry outages. We were also aware that action was underway within NRC to revise General Design Criterion (GDC) 4 to reflect this change in the design bases.

However, because the schedule for that effort was indefinite, it seemed prudent to us at the time to pursue the only route with clear guidance available. Now the revised GDC-4 has been made a final rule, published in the Federal Register (51FR12502) and effective May 12, 1986.

Based on discussions with Mr. L. Rubenstein of NRC on April 15, 1986, and consistent with the intent of the revised rule, we are now revising our initial November 5, 1985, submittal from an exemption request pursuant to 10CFR50.12 to a request for a license amendment pursuant to 10CFR50.90.

The information submitted in support of our original request, referenced above, forms the bases for our revised request. We understand that no additional information is required. We also request that the Application Fee submitted November 5, 1985, now be applied to this request.

This request has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Safety Evaluation and Control Staff. It has been determined that this request does not involve an unreviewed safety question as defined in 10CFR50.59 and does not pose a significant hazards consideration as defined in 10CFR50.92. We note, however, that in the Commission's response to Issue 5 in the Supplementary Information accompanying publication of the revised GDC-4 (51FR12504), statements are made that eliminating pipe whip restraints would not involve an unreviewed safety question, but that changing support load path designs would involve an unreviewed safety question. Because no additional discussion is presented describing the bases for these conclusions, it is not apparent where our evaluation differs from NRC' s. However, because of this apparent conflict, it seems prudent to submit this change to the NRC for review and approval.

Although we are not requesting that this proposed amendment be handled on an exigent ba:sis at this time, we are providing an explanation in Attachment 2 why this request may become exigent. We would appreciate your timely support in processing this amendment should it become necessary to handle it in an exigent manner.

V~ truly yours,

~l.~

W. L. Stewart

e e VIRGINIA ELECTRIC AND POWER COMPANY TO Mr. Harold R; Denton Attachments

1. Proposed License Condition

2. Discussion of Proposed License Amendment cc: Dr. J. Nelson Grace Regional Administrator NRG Region I I NRG Senior Resident Inspector Surry Power Station Mr. Charles Price Department of Health 109 Governor Street Richmond, Virginia 23219 Mr. Ghandu P. Patel NRG Surry Project Manager PWR Project Directorate No. 2 Division of PWR Licensing-A

e e COMMONWEALTH OF VIRGINIA)

)

CITY OF RICHMOND )

The foregoing document was acknowledged befo.re me, in and for the City and Commonwealth aforesaid, today by W. L. Stewart who is Vice President -

Nuclear Operations, of Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company,

• and the statements in the document are true to the best of his knowledge _and belief.

Acknowledged before me this 0 D day of

• A.-:f 1--*.\ , 1,9 ~ lo My Commission expires: 't=~\o1--1J~>1--~ \ci , 19 ~_I\___

Notary Public (SEAL)

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