ML20304A159

Annual Submittal of Technical Specifications Bases Changes Pursuant to Technical Specification 6.4.J

ML20304A159
Person / Time
Site:	Surry
Issue date:	10/12/2020
From:	Henderson J Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
20-357
Download: ML20304A159 (10)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINI.A 23261 October 12, 2020 U.S. Nuclear Regulatory Commission Serial No.20-357 Attention: Document Control Desk SPS-LIC/SCN RO Washington, D.C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 ANNUAL SUBMITTAL OF TECHNICAL SPECIFICATIONS BASES CHANGES PURSUANT TO TECHNICAL SPECIFICATION 6.4.J Pursuant to Technical Specification 6.4.J, "Technical Specifications (TS) Bases Control Program,"

Dominion Energy Virginia hereby submits changes to the Bases of the Surry TS implemented between October 1, 2019 and September 30, 2020.

Bases changes to the TS that were not previously submitted to the NRC as part of a License Amendment Request were reviewed and approved by the Facility Safety Review Committee. It was determined that the changes did not require a revision to the TS or operating licenses, nor did the changes involve a revision to the UFSAR or Bases that required NRC prior approval pursuant to 10CFR50.59. These changes have been incorporated into the TS Bases. A summary of these changes is provided in Attachment 1.

TS !3ases changes that were submitted to the NRC for information along with associated License Amendment Request transmittals, submitted pursuant to 10CFR50.90, were also reviewed and approved by the Facility Safety Review Committee. These changes have been implemented with the respective License Amendments. A summary of these changes is provided in Attachment 2.

Current TS Bases pages reflecting the.changes discussed in Attachments 1 and 2 are provided in .

• If you have any questions regarding this transmittal, please contact Stephen C. Newman at (757) 365-3397.

Very truly yours, Johnny Henderson Director Station Safety and Licensing Surry Power Station Attachments: 1. Summary of TS Bases Changes Not Previously Submitted to the NRC

2. Summary of TS Bases Changes Associated with License Amendments

3. Current TS Bases Pages Commitments made in this letter: -None

Serial No.20-357 Docket Nos 50-280, 50-281 Page 2 of 2 cc: U.S. Nuclear Regulatory Commission Region II

• Marquis One Tower 245 Peachtree Center Avenue NE Suite 1200

• Atlanta, Georgia 30303-1257 State Health Commissioner Virginia Department of Health James Madison Building - 7th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. V. Thomas NRC Project Manager U. S. Nuclear Regulatory Commission Mail Stop O 4F 12 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. G. E. Miller NRC Senior Project Manager U. S Nuclear Regulatory Commission Mail Stop O 9E 3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector Surry Power Station

Attachment 1 Serial No.20-357 Summary of TS Bases Changes Not Previously Submitted to the NRC Surry Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion Energy Virginia)

Serial No.20-357 Docket Nos 50-280, 50-281 Attachment 1

SUMMARY

OF TS BASES CHANGES NOT PREVIOUSLY SUBMITTED TO THE NRC TS 3. 7 Bases Revision This TS 3.7 Bases revision (TS page 3.7-3) clarifies that the Intermediate Range and Power Range Channel Calibrations may be performed online. It also removes text related to dropped rod protection based on the implementation of Design Change 94-007-03, Removal of Turbine Run Dropped Rod/Surry/Units 1&2. The TS 3.7 Bases change was implemented on April 30, 2020.

Page 1 of 1

Attachment 2 Serial No.20-357 Summary of TS Bases Changes Associated with License Amendments Surry Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion Energy Vlrglnia)

Serial No 20-357 Docket Nos. 50-280, 50-281 Attachment 2

SUMMARY

OF TS BASES CHANGES ASSOCIATED WITH LICENSE AMENDMENTS Bases change associated with Technical Specification 3.16 License Amendment Request (Ref.: LBDCR TSCR 457).

Revision of TS 3.16 provided a temporary 14-day allowed outage time (AOD for replacement of the C Reserve Station Service Transformer (RSST C) 5KV cables to transfer bus F.

Revision to the TS 3.16 Bases (TS pages 3.16-7 and 3.16-8) was associated with the temporary 14-day Allowed Outage Time. These changes were incorporated into the Bases as part of License Amendments 297/297 implemented on April 30, 2020.

Page 1 of 1

Attachment 3 Serial No.20-357 Current TS Bases Pages Surry Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion Energy Virginia)

TS 3.7-3 03-26-20

b. With two trains inoperable, isolate the MCR/ESGR envelope normal ventilation immediately or be in at least HOT SHUTDOWN within the next six (6) hours and be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

2. During the movement of irradiated fuel assemblies:

a. With one train inoperable, within seven (7) days either isolate the MCR/ESGR envelope normal ventilation or suspend movement of irradiated fuel assemblies.

b. With two trains inoperable, immediately isolate the MCR/ESGR envelope normal ventilation or immediately suspend movement of irradiated fuel assemblies.

Basis Instrument Operating Conditions During plant operations, the complete instrumentation system will normally be in service.

Reactor safety is provided by the Reactor Protection System, which automatically initiates appropriate action to prevent exceeding established limits. Safety is not compromised, however, by continuing operation with certain instrumentation channels out of service since provisions were made for this in the plant design. This specification outlines the limiting conditions for operation necessary to preserve the effectiveness of the Reactor Protection System when any one or more of the channels is out of service.

Almost all Reactor Protection System channels are supplied with sufficient redundancy to provide the capability for channel calibration and test at power. Exceptions are backup channels such as reactor coolant pump breakers. The removal of one trip channel on process control equipment is accomplished by placing that channel bistable in a tripped mode (e.g., a two-out-of-three circuit becomes a one-out-of-two circuit). Testing does not trip the system unless a trip condition exists in a concurrent channel. The Nuclear Instrumentation System (NIS) channels are not intentionally placed in a tripped mode during testing since the test signal is superimposed on the normal detector signal to test at power. Intermediate range and power range channel calibration can be performed at power. Testing of the NIS power range channel requires: (a) placing the LiTfT avg protection channel set that is being fed from the NIS channel in the trip mode and (b) defeating the power mismatch section of Tavg control channels when the appropriate NIS channel is being tested. Maintenance and/or calibration of the NIS intermediate range and power range channels can be performed at power or during shutdown conditions. However, to perform calibration at power the detector signal cable must be disconnected from the channel's drawer and the associated NIS channel placed in the trip mode.

Amendment Nos. Bases

TS 3.16-7 03-16-20 TS action statement 3 .16.B .1.a.2 provides an allowance to a void unnecessary testing of an OPERABLE EDG(s). If it can be determined that the cause of an inoperable EDG does not exist on the OPERABLE EDG(s), operability testing does not have to be performed. If the cause of the inoperability exists on the other EDG(s), then the other EDG(s) would be declared inoperable upon discovery, and the applicable required action(s) would be entered. Once the failure is repaired, the common cause failure no longer exists and the operability testing requirement for the OPERABLE EDG(s) is satisfied. If the cause of the initial inoperable EDG cannot be confirmed not to exist on the remaining EDG(s),

performance of the operability test within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provides assurance of continued operability of those EDG(s).

In the event the inoperable EDG is restored to OPERABLE status prior to completing the operability testing requirement for the OPERABLE EDG(s), the corrective action program will continue to evaluate the common cause possibility, including the other unit's EDG or the shared EDG. This continued evaluation, however, is no longer under the 24-hour constraint imposed by the action statement.

According to Generic Letter 84-15 (Ref. 6), 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable to confirm that the OPERABLE EDG(s) is not affected by the same problem as the inoperable EDG.

Reserve Station Service Transformer (RSST) C is the primary offsite power source for the 1H and 2J Emergency Buses via transfer bus F. To facilitate the replacement of the RSST C 5KV cables to transformer bus F during the Spring 2020 Unit 2 refueling outage, Technical Specification 3.16.B.2 is modified by a footnote permitting the use of a temporary, one time, 14-day allowed outage time (AOT). The 14-day AOT will permit Unit 1 to continue to operate for 14 days. While RSST C is unavailable to facilitate replacement of the RSST C 5KV cables, transfer bus F will be powered from the dependable alternate source (i.e, backfeed through the Unit 2 Main Step-up Transformer/

Station Service Transformer 2C). The backfeed power supply will allow transfer bus F to perform its normal function while the RSST C 5KV cables are being replaced. Prior to entry into the 14-day AOT, the following actions shall be taken:

1. Within 30 days prior to entering the temporary 14-day AOT, functionality of the Alternate AC (AAC) System (i.e., the supplemental power source) shall be verified.

2. During the 14-day AOT, the functionality of the AAC System shall be checked once per shift. If the AAC System becomes non-functional at any time during the 14-day AOT, it shall be restored to functional status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or the unit shall be brought to HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Amendment Nos.297 and 297

TS 3.16-7a 03-16-20 The verification of functionality of the AAC System prior to entering the temporary 14-day AOT will be based on the previous satisfactory quarterly test. The once per shift functionality check will be performed during shiftly operator rounds.

In addition to verifying and checking functionality of the AAC System prior to and during the temporary 14-day AOT, the following actions will also be taken:

• Weather conditions will be monitored and preplanned maintenance will not be scheduled if severe weather conditions are anticipated.

• The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the temporary 14-day AOT.

• Component testing or maintenance of safety systems and important non-safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided. In addition, no discretionary switchyard maintenance will be performed.

• TS required systems, subsystems, trains, components, and devices that depend on the remaining power sources will be verified to be operable and positive measures will be provided to preclude subsequent testing or maintenance activities on these systems, subsystems, trains, components, and devices.

• Operation or maintenance of plant equipment when its redundant equipment or train is out of service will be controlled in accordance with procedure OP-SU-601, "Protected Equipment." The Unit 1 steam-driven Auxiliary Feedwater Pump will be controlled as "Protected Equipment" during the temporary 14-day AOT.

• The status of the AAC diesel generator, EDGs, RSST A and RSST B will be monitored once per shift.

Amendment Nos.297 and 297