ML18153B974

Application for Amends to Licenses DPR-32 & DPR-37,modifying Pressurizer Safety Valve Setpoint Tolerance in Tech Spec 3.1.A.3.c for Remainder of Cycle 10

ML18153B974
Person / Time
Site:	Surry
Issue date:	11/10/1989
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18153B975	List: ML18153B974 ML18153B976
References
89-750A, NUDOCS 8911160247
Download: ML18153B974 (4)

Text

- VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 e

November 10, 1989 United States Nuclear Regulatory Commission Serial No. 89-750A Attention: Document Control Desk NO/ETS R1 Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PRESSURIZER SAFETY VALVE SETPOINT EMERGENCY TECHNICAL SPECIFICATION CHANGE REQUEST Pursuant to 10 CFR 50.90, the Virginia Electric and Power Company requests an emergency amendment, in the form of a change to the Technical Specifications, to Operating Licenses No. DPR-32 and DPR-37 for Surry Power Station Units 1 and 2, respectively. Based on the potential generic safety valve setpoint testing issue recently identified, our recently completed Unit 2 safety valve setpoint testing results and the subsequent recent lift of a Unit 2 pressurizer safety valve during pressure testing, we are requesting that the +/- 1% setpoint tolerance of Technical Specification 3.1.A.3.c be modified for the remainder of Cycle 1O for both units. This change is requested due to the potential that the Unit 1 and 2 safety valve setpoints are outside the current + 1% tolerance required by the existing Specifications due to setpoint testing methodology. The safety valve testing methodology issue and the results of the Unit 2 safety valve testing were reported to the NRC in our letter 89-750, dated October 30, 1989. The requested Technical Specification change, discussion, and significant hazards consideration are provided in Attachments 1 and 2.

At the time this issue was identified, Unit 2 was shutdown and the safety valves could be readily tested. We chose to test the Unit 2 valves on a water loop seal and on steam and have them reset on a water loop seal to eliminate the setpoint shift due to testing methodology. We applied the Unit 2 test findings to the Unit 1 valves and notified the NRC of the potential Technical Specification noncompliance (>+ 1 %

setpoint tolerance). As documented in a NRC letter of October 27, 1989, we received 6 weeks of discretionary enforcement to work with the N RC and the industry to resolve the issue. On November 6, 1989, during RCS pressure testing prior to Unit 2 return to service, the recently reset 'C' pressurizer safety valve lifted due to an apparent loss of loop seal. Based on this recent event, we have decided to reset the Unit 2 valves using the previous methodology (steam) to minimize the potential for challenges of the pressurizer safety valves and seek similar relief from Technical Specification 3.1.A.3.c for Unit 2 pending generic resolution of this issue. To date, generic resolution of this issue has not been reached by industry or the NRC; and therefore, we request this Technical Specification change ~ce*ssed as an emergency change per 10 CFR 50.91 for continued operation .of Unit 1 and the restart of Unit 2 after resetting the 8911160247 891110 \

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pressurizer safety valves on steam. The explanation for the emergency processing of this change is provided in Attachment 3.

The proposed Technical Specification change modifies pressurizer safety valve lift setpoint tolerances to -1 % and +5%, which encompasses any observed increase in setpoint shift identified during testing of the Unit 2 safety valves. This modified tolerance remains within the safety analysis bounds. Although no additional measures are necessary based on the setpoint tolerance proposed and the safety analyses, due to the uncertainties and the unquantified variables associated with safety valve testing, we will perform appropriate measures to provide added assurance that primary pressure can not exceed 2750 psig (110% of system design).

These measures, which will apply to each unit, are the same measures as we are currently applying as part of discretionary enforcement for Unit 1. They include the continued operability of at least one of the two Power Operated Relief Valves (PORV) and the anticipatory reactor trip on turbine trip circuitry. With these measures in place, any analyzed UFSAR transient would result in peak pressure remaining below 2750 psig, even if the setpoints were to increase to a value higher than the +5% proposed limit.

In addition, we wm continue to work with the NRC, industry and Owners groups to determine and expedite a satisfactory resolution to this potential generic issue in order to support the end of Cycle 10 application of this proposed Technical Specification change.

These requests have been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Safety Evaluation and Control Staff. It has been determined that the proposed Technical Specification change does not involve an unreviewed safety question as defined in 10 CFR 50.59 or a significant hazards consideration as defined in 10 CFR 50.92. The basis for our no significant hazards consideration determination is included in Attachment 2.

Should you have any additional questions, please call.

Very truly yours, J.s~

. L. Stewart e ior Vice President - Nuclear Attachments

1. Proposed Technical Specification Change

2. Discussion of Proposed Change and Significant Hazards Consideration

3. Justification for Emergency Technical Specification Change Request

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 Commissioner Department of Health Room 400 109 Governor Street Richmond, Virginia 23219

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COMMONWEALTH OF VIRGINIA )

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COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. L. Wilson who is Assistant Vice President - Nuclear Operations, for W. L. Stewart who is Senior Vice President - Nuclear, 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 ./Jzffday oi<p,k.,; , 1931.

My Commission Expires: ~.b~ ZS. 19~.

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Notary--#i:iubl ic (SEAL)-<:

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