ML18149A221
| ML18149A221 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/18/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Rubenstein L Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 86-191B, NUDOCS 8607240283 | |
| Download: ML18149A221 (3) | |
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ViRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PRESIDENT NUCLEAR QpERATlONS July 18, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation Attn:
Mr. Lester S. Rubenstein, Director PWR Project Directorate No. 2 Division of PWR Licensing-A U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT NOS. 1 AND 2 REGULATORY GUIDE 1.97 - SCHEDULE EXTENSION REQUEST Serial No.
NO/ETS:vlh Docket Nos.
License Nos.
86-191B 50-280*
50-281 DPR-32 DPR-37 Your Confirmatory Order of June 14, 1984 specified a completion schedule for commitments to Supplement 1 to NUREG-0737 for Surry Power Station.
The order required Surry Power Station to have Regulatory Guide 1. 97 variables installed or upgraded, including the Containment Isolation Valve Position Indication (B-14), by the first refueling outage after July 1, 1985, for both units. Unit 1 has just completed this refueling outage and returned to service July 18, 1986.
The corresponding Unit 2 refueling outage is currently scheduled for October 3 through November 20, 1986.
This Confirmatory Order also contained a provision allowing the Director, Division of Licensing, to grant extensions of time for completing the identified items "for good cause shown".
In accordance with this provision, we are requesting a schedule extension until the 1988 refueling outages for Unit Nos. 1 and 2 to engineer, procure and install qualified limit switches utilized to provide position indication for three containment isolation valves per unit in the sampling system.
It is our intention to install qualified limit switches in the shortest.possible time frame based on scheduled unit outages consistent with completion of design and procurement.
This request will be subject to a more detailed engineering review to assess whether the requested schedule extension can be improved.
The results of our engineering assessment and an installation schedule will be forwarded to you by September 5, 1986.
Limit switches were installed on the required isolation valves.
- However, limit switches on three valves in the Sample System (mark numbers TV-SS-lOOA, 101A and 104A) failed during a recent containment Type "A" test which prevents them from being environmentally qualified for use in containment.
The limit switches that failed are different in design and manufacture than the other qualified limit switches that have been installed in containment as part of our Regulatory Guide 1.97 commitment.
8607240283 860718 PDR ADOCK 05000280 P
This difference is due to the design characteristics of the containment isolation trip valves with which they are associated.
Due to this recent failure, additional time is required to engineer, procure and install, qualified limit switches or alternative valve indication in Unit 1.
Additionally, the same design limit switches that failed,during the Unit 1 Type "A" test were scheduled to be installed during the upcoming Uriit 2 refueling outage.
Therefore, an extension is also requested for the same three valve limit switches (Mark No.
TV-SS-200A, 201A and 204A) in Unit 2.
Until that time, the unqualified replacement limit switches will be used in Unit 1 and the existing limit switches will remain in Unit 2.
To ensure containment integrity for these three Unit 1 sample lines, the trip valves inside containment have been closed and deenergized.
Similar compensatory actions will be taken on the Unit 2
sample lines. following its 1986 refueling outage if qualification is not accomplished.
In addition, the outside containment isolation valve limit switches are environmentally qualified and provide positive indication of valve position and thereby indication of containment isolation.
In any event, qualification will be achieved on the position *.ndication for these 3 valves in each unit no *later than the end o.~ the associated 1988 refueling outages.
With the exc8ption of these valves, containment isolation valves have or will have qualified position indication installed in accordance with the completion schedule of the Confirmatory Order.
We had committed to upgrading limit switches on containment isolation valves in accordance with our previous equipment qualification commitments.
During a March 19, 1984 meeting between the NRC and the Company on equipment qualification, it was agreed to incorporate and complete certain of these environmental qualification items under the Regulatory Guide 1.97 implementation schedule.
This included the three containment isolation valve position indicators.
This agreement was documented in a Virginia Electric and Power Company letter, Serial No.86-286, dated January 11, 1985.
We failed to recognize that this agreement should have been incorporated and clarified in the supporting bases (Virginia Electric and Power Company letters of January 31, 1984 and February 21, 1984) for the Confirmatory Order.
As noted in the Confirmatory Order, our commitments were made to complete the basic requirements for emergency response capability.
Including the variable of containment isolation valve position indication under the schedule of the Confirmatory Order is consistent with that intent.
We therefore request that you specifically include this variable within the provisions of the Order and grant the requested schedule extension for the three containment isolation valve position indicators per unit.
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This letter supplements our previous schedule extension request on April 21, 1986, (Serial No.86-191) for completion of Regulatory Guide 1.97 and SPDS commitments.
If you have questions concerning this matter, please contact us.
Very truly yours, W. L. Stewart cc:
Dr. J. Nelson Grace Regional Administrator NRC Region II NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager PWR Project Directorate No. 2 Division of PWR Licensing-A