ML18153C303

Advises of Withdrawal of Request for NRC Review & Approval of Engineering Evaluation 8.Revised Evaluation Will Be Maintained Onsite for NRC Audit During Future Insps,Per Generic Ltr 86-10

ML18153C303
Person / Time
Site:	Surry
Issue date:	07/26/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-404, GL-86-10, NUDOCS 9008010199
Download: ML18153C303 (2)

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• .. 'v VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 26, 1990 United States Nuclear Regulatory Commission Serial No.90-404 Attention: Document Control Desk NL&P/JDH/TAH 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 APPENDIX R ENGINEERING EVALUATIONS On April 10, 1986 (Serial No.85-781 ), we submitted four engineering evaluations related to certain Appendix R fire protection features at Surry for which we requested NRG review and approval. During the North Anna Power Station triennial Appendix R inspection conducted by NRG Region II on July 18-22, 1988, NRG inspectors identified a concern with two of the North Anna engineering evaluations, and this concern directly applies to one of Surry's engineering evaluations. The evaluation is titled: "8. Evaluation of Operator Access to the Charging Pump Cubicles." The evaluation included and justified that reentry into the affected fire area within thirty minutes to take certain manual actions is feasible.

The inspector's concern was discussed in NRG Inspection Report No. 50-338, 339/88-13, dated September 13, 1988, in which the inspector questioned the validity of the reentry time assumption supporting the engineering evaluations. Traditionally, NRG has not approved entry into a fire area to take manual operations to mitigate the consequences of a fire in less than sixty minutes of a fire event. The issue was designated Unresolved Item 88-13-02, and Region II requested technical assistance from NRR to determine the acceptability of the evaluations.

We have subsequently reevaluated the reentry time assumption contained in that evaluation. Specifically, through analysis we have been able to extend the period described in the evaluation from thirty to sixty minutes prior to requiring reentry into the affected fire area. On April 4, 1990, we* met with 90080101QQ Pr: R ** * -)~~1-

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' Serial No.90-404 Docket Nos. 50-280 & 281 License Nos. DPR-32 & 37 Messrs. L. Engle and D. Notley of NRR to describe our revised analysis as it relates to the North Anna engineering evaluations. Our revised analysis has been completed and applies equally to the Surry evaluation.

Based on establishing a sixty minute interval prior to requiring reentry into the fire area and our subsequent discussions with NRR staff, we are withdrawing our request for NRC review and approval of Engineering Evaluation No. 8. Rather, the revised evaluation will be maintained onsite for NRC audit during future inspections as permitted by Generic Letter 86-10, "Implementation of Fire Protection Requirements," Paragraph C, dated April 24, 1986.

Should you have any questions, please contact us.

Very truly yours, W. L. Stewart Senior Vice President - Nuclear Attachment cc: United States Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Suite 2900 Atlanta, Georgia 30301 Mr. W. E. Holland NRG Senior Resident Inspector Surry Power Station