ML18152B283

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Responds to Generic Ltr 88-11 Re Embrittlement of Reactor Vessel Beltline Matls,Per Reg Guide 1.99,Rev 2.Proposed Tech Specs Which Implement Rev 2 to Reg Guide 1.99 Under NRC Review
ML18152B283
Person / Time
Site: Surry  Dominion icon.png
Issue date: 11/30/1988
From: Cartwright W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.099, RTR-REGGD-1.099 88-492, GL-88-11, NUDOCS 8812060102
Download: ML18152B283 (2)


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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. R. CARTWRIGHT VICE PRESIDENT NUCLEAR November 30, 1988 U. S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C.

20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY RESPONSE TO GENERIC LETTER 88-11 SURRY POWER STATION UNITS 1 AND 2 Serial No.

PES/DMB:cdk Docket Nos.

License Nos.88-492 50-280 50-281 DPR-32 DPR-37 Generic Letter 88-11 requires a submittal to provide details of the implementation of Regulatory Guide 1.99, Revision 2 in analyses, other than pressurized thermal shock (PTS), that require an estimate of the embrittlement of reactor vessel beltline materials.

Technical analyses necessary to determine the impact of Revision 2 are to be summarized and a proposed schedule for implementation of necessary actions is required.

The generic letter states that all required actions should be completed within two (2) plant outages (approximately 3 years).

Virginia Electric and Power Company proposed implementing the methodology of Regulatory Guide 1.99, Revision 2 into the heatup and cooldown curves for Surry in a January 29 9 1988 letter (Serial No. 87-223C).

This letter contained the proposed Technical Specification changes resulting from the latest surveillance capsule analysis.

The impact of the proposed change on the Surry heatup and cooldown curves is substantial in terms of reduced operating space. It is clear that plant operation will become increasingly more restrictive beyond the proposed validity date of 15 EFPY unless some margin can be identified.

In order to support a request for relief, Virginia Electric and Power Company is pursuing several options. First, the company is an active participant in the Electric Power Research Institute (EPRI) radiation embrittlement program which represents an industry effort to solve several issues resulting from increased embrittlement i_ncluding the decreasing operating window on the heatup and cooldown curves. Additionally, the company is in the process of joining the Babcock & Wilcox Owners Group materials committee.

Membership in this group is appropriate because some of the welds in the Surry vessels were made by B&W prior to completion of the vessels by another contractor. These two efforts are the programmatic means being used to identify areas/items where relief may be justified and thereby provide additional operating margin.

Since these efforts are just beginning, it is too early to predict how much additiona_.l margin can be obtained.

A0o<t" 1\\1

e In summary, proposed Technical Specifications which implement Regulatory Guide 1.99, Revision 2 in the appropriate Technical Specifications are currently under USNRC review.

Supplemental information on this proposed Technical Specification is forthcoming.

These changes include revised LTOP setpoints.

Additionally, since the revised curves are more restrictive at lower temperatures than the current T.S. heatup and cooldown curve a composite of the curves has been administratively implemented to ensure conservative limits pending approval of the proposed heatup and cooldown curves.

At this point no other activities are scheduled, The programmatic options are being pursued to provide relief for operation after 15 EFPY.

Very truly yours, vf'~ ~~ctwc.100}

W. R. Cartwright Attachments cc:

U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr, W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager Project Directorate II-2 Division of Reactor Projects - I/II