ML18151A099
| ML18151A099 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/02/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-616, NUDOCS 8710080460 | |
| Download: ML18151A099 (2) | |
Text
e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PRESIDENT NUCLEAR OPERATIONS October 2, 1987 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 CONFIRMATION OF DISCRETIONARY ENFORCEMENT Serial No.87-616 NO/ JDH:jmj :R6 Docket No. 50-280 License No. DPR-32 This letter documents our understanding of October 1, 1987 pertaining to the exercise by NRC Region II of discretionary enforcement regarding compliance with Surry Technical Specification 4.7, Main Steam Trip Valves.
Prior to restart of Surry 1 on September 29, 1987 subsequent to a maintenance
- outage, compliance with Technical Specification 4.7 could not be adequately demonstrated.
Specifically, the Main Steam Trip Valve closure time of five seconds specified in the current Technical Specification could not be achieved without steam flow.
Actual times were 5.37 to 7.22 seconds.
Difficulty in meeting the acceptance criteria had been encountered in earlier tests.
Subsequent to the December 9, 1986 event at Surry 2, we undertook an intense effort to improve MSTV maintenance procedures.
We have achieved significant improvements in this area and we believe revised test acceptance criteria are warranted.
We believe that a
revised procedure using an acceptance criteria based on the main steamline break accident analysis assumptions would be an acceptable test of the MSTV closure capability.
- However, we understand that additional documentation regarding the accident analysis assumptions as the bases for the MSTV technical specification is
- desired, based on information currently available to NRC on the docket.
This need for additional information in describing the current accident analysis assumptions resulted in our recent request that NRC Region II consider discretionary enforcement of TS 4.7 until a revised specification, its bases, and the supporting accident analysis assumptions can be reviewed and approved by NRC.
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Based on communications with NRC management, we understand that discretionary enforcement was granted to permit Unit 1 startup subject to our submittal by October 9, 1987 of a proposed Technical Specification change that clearly specifies the surveillance test acceptance criteria, the bases, and the supporting accident analyses assumptions.
We understand that the discretionary enforcement is a one-time only approval pending action on the proposed Technical Specification change.
In the interim, we have evaluated the ability of the MSTVs to perform their safety function in the event of a main steamline break event and conclude that, based on the closure times documented in the most recent surveillance test, the offsite dose consequences remain a small fraction of the 10 CFR Part 100 guidelines and the conclusions of the current accident analyses remain valid.
Very truly yours,
~\\__~,
W. L. Stewart cc:
U.S. Nuclear Regulatory Commission 101 Marietta Street, NW Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station