ML18153D167
| ML18153D167 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/10/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-652, NUDOCS 9211160081 | |
| Download: ML18153D167 (2) | |
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e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 November 10, 1992 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 Serial No.
NO/ETS Docket Nos.
License Nos.92-652 50-280 50-281 DPR-32 DPR-37 REQUEST FOR EXEMPTION FOR ASME SECTION XI INTERVAL DATES FOR INSERVICE TESTING PROGRAMS FOR PUMPS AND VALVES 1 O CFR 50.55a (g)(4)(ii) requires inservice testing of pumps and valves to be performed in successive 120-month intervals beginning with the completion of the initial 120 month interval. This testing shall comply with the requirements of the latest edition of the Code and addenda incorporated by reference in paragraph (b) of this section.
Due to extended maintenance outages, both Surry Units 1 and 2 have extended their inservice testing intervals in accordance with the provisions of the Code. However, the interval start dates are different by seven months. Pursuant to 1 O CFR 50.12, we are requesting an exemption from the requirements of 1 O CFR 50.55a (g)(4)(ii) to postpone the Unit 1 third interval inservice testing start date until May 10, 1994, to coincide with the Unit 2 third interval start date.
Specifically, 1 O CFR 50.12 (a}(2}(ii) states in part, that the NRC will consider granting an exception whenever application of the regulation is not necessary to achieve the underlying purpose of the rule. The Surry Unit 1 second interval inservice testing program will continue to be implemented in accordance with the existing approved program until the start of the third interval. Therefore, the operational readiness of the pumps and valves, whose function is required for safety, will continue to be assured until the third interval commences on May 1 O, 1994. Continued implementation of the existing second interval program meets the underlying purpose of the regulations.
The following administrative benefits result from the Unit 1 third interval start date being postponed to coincide with the corresponding Unit 2 third interval start date.
The lnservice Testing Programs for Units 1 and 2 would be on and remain on the same interval and require compliance with the same edition of the code and addenda.
Therefore, the testing requirements would be consistent. This will simplify our program preparation, review and administration for the third interval, as well as the associated program review by the NRC. Likewise, any relief requests submitted during the third
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""interval would be similarly simplified. A common start date will also reduce the program administration burden by permitting only a single submittal to be made for both units.
ENVIRONMENTAL IMPACT The proposed exemption would provide. a degree of lnservice Testing that is equivalent to that required by 1 O CFR 50.55a (g)(4)(ii) such that there would be no decrease in the operational readiness of pumps and valves whose function is required for safety. Consequently, the probability of malfunction of components would not be increased, the radiological risk would not be greater than determined previously, and the requested exemption would not otherwise affect plant radiological effluents.
With regard to potential nonradiological impacts, the proposed exemption involves features located entirely within the restricted area as defined in 1 O CFR Part 20. It would not affect plant nonradiological effluents and would have no other environmental impact.
We conclude that there are no significant radiological or nonradiological environmental impacts associated with the proposed exemption.
In addition, we conclude that an environmental impact statement for the proposed exemption is unnecessary.
Based upon the foregoing environmental assessment, we have concluded that approval of the proposed action will not have a significant effect on the quality of the human environment.
If you require additional information, please contact us.
Very truly yours, 1Jl W. L. Stew cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station