ML18153C002
| ML18153C002 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/13/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Lieberman J, Murley T, Taylor J NRC OFFICE OF ENFORCEMENT (OE), Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 8912080095 | |
| Download: ML18153C002 (6) | |
Text
OFFICIAL NOV 1 3 mag MEMORANDUM FOR:
James M. Taylor, Acting Executive Director for Operations Thomas E. Murley, Director, Office of Nuclear Reactor Regulation FROM:
SUBJECT:
James Lieberman, Director, Office of Enforcement Stewart D. Ebneter, Regional Administrator ENFORCEMENT DISCRETION - SURRY UNIT 2 DOCKET NO. 50-281 On November 9, 1989, Region II excercised enforcement discretion for Surry Unit 2.
The discretion provided a ten-day period (through November 19, 1989) for simultaneous removal of all three pressurizer safety valves. _ Technical Specification 3.1.A.3.a requires that 110ne valve shall be operable whenever the head is on the reactor vessel, except during hydrostatic tests." A recent evint occurred in which the "C" pressurizer safety valve prematurely lifted during the reactor coolant system overpressure test while the licensee was returning the unit to service.
Due to this event, the licensee has decided to remove all three pressurizer safety valves for testing and setpoint adjustment.
In order to avoid an adverse impact on Unit 2 restart, the licensee verbally requested d_iscretionary enforcement on November 9, following with a formal request by letter dated November 9, 1989.
Region !I's rationale for granting this discretion was based primarily on the technical justifications provided by the licensee in their request submittal dated November 9, 1989.
The basis of Technical Specification 3.1.A.3.a is to '
prevent ov~rpressurization events whenever reactor coolant system integrity is maintained.
We believe that with the unit in a cold shutdown condition, removal of the pressurizer safety valves does provide-an equivalent relief path to-prevent any overpressurization event.
Also, it is our opinion that the foreign material exclusion covers, which consists of a -light gasket material, do not adversely impact the relief capacity of the vacant valve sites.
The basis for the ten-day time frame was to allow sufficient time for the licensee to remove, test, and return at least one safety valve to*
service to satisfy the Technical Specification requirements.
Technical-discussions on this matter took p 1 ace on November 9, between the 1 i censee and the NRC, specifically, H. Bt::rkow, B. Buckley, and C. Moon of NRR; and C. Hehl, M. Sinkule, W. Holland and S. Shaeffer of Region II.
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8912080095 891113 PDR ADOCK 05000280
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Multiple Addressees 2
NOV 1 3 1989
- NRR-concurrence with our actions was obtained on November 9, 1989,- by phone call between G. Lainas, H. Berkow, B. Buckley, and C. Moon of NRR;* and J. Milhoan, C._ Hehl, M. Sinkule and W. Holland of Regi6n II.
Subsequ~nt to these discussions, I* approved the discretionary enforcement action and the licensee was notified.
A copy of the Virginia Power submittal and authoriza-tion are enclosed.
Enclosures:
- 1. Virginia Power ltr dtd November 9. 1989
- 2.
Region II ltr to VEPCO dtd November 13,* 1989 cc w/encTs:
S. Varga, NRR H. Berkow, NRR B. Buckley, NRR.
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ENCLOSURE 1 VraoOOA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 232'1 November 9, 1989 Mr. Stewart D. Ebnet1r fllQlonal Admlnlltrator
- Serial No.89-791 NLJRPC Unhd States Nuclear Regulatory Commission Pleglon II.
- 101 Marietta Strut, N. W.
8ulta 2900 Docket No.
50-281 L1eens1 No.
OPA-32 Attantl, Georgia 30323
Dear Mr. Ebneter:
Technical Specification 3.1.A.3.a. reQulres that "One valve shall be operable whenever the head Is on the reactor vessel, except during hydrostatic tests: To allow for simultaneous testing of the three pressurizer safety valves to avoid an adverse Impact on Unl1 2 restart, discretionary enforcement has been requested-.
. A1 discussed In a telephone conversation with your staff on November 9, 1989,
- Virginia Electric an~ Power Company was granted discretionary enforcement for a period of ten* days (through November 19, 1989) to provide for the simultaneous l'lmoval of the three pressurizer safety valves.
This request was made due the recent pressurizer safety valve 11ft during the RCS overpressure test while returning the unit to service. Based on this event, we have d8eldtd to test and reset the three Unit 2 valves.
Unit 2 Is presently In cold shutdown. Our technical Justification for this request is as followa:
(1)
(2)
The bases
- of TechnlcJI Specification 3.1.A.3.a Is to prevent overpressurlzatlon events whenever RCS Integrity Is maintained.
Removal of the safety valves provides an equivalent relief path to prevent any overpressurlzation event.
The foreign material exclusion cover has been previously analyzed In terms of Its Impact on rellef capacity. This analysis determined that such excluslon cove~ do not adversely impact the relief capacity of the vacant vatvt lftee.
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(3)
Furthermore, AHR relltf and PORV capacity provides addltlonal protection from overpresaurlzatlon.
We conclude that removal of the safety valves and use of the vacant valve site with foreign material exclusion covers provides the equivalent overpressurlzatlon
- protection ** an operable 1aftty vatvt.
Should you have any further qu11stlons or require any additional* Information, please contact UI, cc:. U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C; 20555 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Sta11Qn
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NOV 1 3 1989 Docket No~ 50-281 License No. DPR-37 Virginia Electric ar,d Power Company ATTN:
Mr. W. L. Stewart Senior Vice Pr~sident - Power 5000 Dominion Boulevard Glen Allen, VA 23060 Gentl~en:
SUBJECT:
ENFORCEMENT DISCRETION - SURRY UNIT 2 This letter confinns ttie telephone conversation between Mr. R. Saunders of your staff arid Mr. C. Hehl of my staff on November 9, 1989, granting enforcement discretion for Surry Unit 2.
Our action was based on your verbal request on November 9, 1989, as documented in your letter issued on November 9, 1989.
Technical Specification 3.1.A.3.a requires that "One valve shall be operable whenever the head is on the reactor vessel, except during hydrostatic tests."
The discretion provided a ten-day period (through November 19, 1989) for simultaneous removal of the three pressurizer safety valves on Unit 2, and was based on the technical justi.fication provided in your request letter dated*
- November 9, 1989.
- Should you ~ave any questions concerning this l~tter, please contact us.
cc: W.R. Cartwright Vice President - Nuclear Operations Virginia E1~ctric*& Power Company 5000 Dominion Boulevard Gl~n Allen, VA 23060 J.P. O'Hanlon Vice President - Nuclear Services.
Vtrgini~ Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA.23060 cc cont'd:
(See page 2)
Sincerely,
'"-lva *.
tewart D. Ebneter Regional Administrator
e Virginia Electric and Power company cc cont'd:
M. R. Kansler Station Manager Surry Power Station P. 0. Box 315 Surry, VA 23883 R. F. Saunders, Manager Nuclear Licensing Virginia Electric & Power Co.
5000 Dominion Boulevard Glen Allen, VA. 23060 Sherlock Holmes, Chairman 2
Board of Supervisors of Surry County Surry County Courthouse Surry, VA 23683 W. T. Lough Virginia Corporation* Coll'ITlission Division of Energy Regulation P.O. Box 1197 Richmond, VA 23209 Michael W. Maupin Hunton and Williams P. 0. Box 1535 R~chmond, VA 23212 C. M. G. Buttery, M.D., M.P.H.
Department of Health 109 Governor Street Richmond, VA. 23219 Attorney Genera.l Supreme Court Building 101 North 8th Street Richmond, VA 23219 Commonwealth of Vir9inia NOV t 3 1989