ML24088A248
| ML24088A248 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/26/2024 |
| From: | James Holloway Virginia Electric & Power Co (VEPCO) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 24-109 | |
| Download: ML24088A248 (1) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 26, 2024 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 10 CFR 50.55a Serial No.24-109 NRA/GDM RO Docket Nos.
50-280/281 License Nos.
DPR-32/37 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES SIXTH INTERVAL UPDATE AND ASSOCIATED RELIEF AND ALTERNATIVE REQUESTS-RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated October 12, 2023 (Agencywide Documents Access and Management System Accession No. ML23285A092), Virginia Electric and Power Company (Dominion Energy Virginia) submitted Relief Request P-2 for the Containment Spray pumps to the U.S. Nuclear Regulatory Commission (NRG) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, paragraph (f)(5)(iii), as part of the Surry Power Station (SPS) Units 1 and 2 Sixth Interval lnservice Testing (1ST) Program.
By email dated March 5, 2024, the SPS NRG Project Manager provided a request for additional information (RAI) associated with Relief Request P-2 to facilitate NRG staff review.
Dominion Energy Virginia's response to the NRG RAI is provided in the attachment.
If you have any questions or require additional information, please contact Mr. Gary D.
Miller at (804) 273-2771.
Respectfully, James E. Holloway Vice President - Nuclear Engineering and Fleet Support Commitments contained in this letter: None
Attachment:
Response to NRG Request for Additional Information, Relief Request P-2
cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. L. John Klos NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852 Mr. G. Edward Miller NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector Surry Power Station Authorized Nuclear Inspector Surry Power Station Serial No.24-109 Docket Nos. 50-280/281 Page 2 of 2
Attachment Serial No.24-109 Docket Nos. 50-280/281 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST P-2 SIXTH INTERVAL INSERVICE TESTING PROGRAM SURRY POWER STATION UNITS 1 AND 2 Virginia Electric and Power Company (Dominion Energy Virginia)
Serial No.24-109 Docket Nos. 50-280/281 Attachment Page 1 of 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST P-2 SIXTH INTERVAL INSERVICE TESTING PROGRAM SURRY NUCLEAR POWER STATION, UNITS 1 AND 2 NRC COMMENT:
Background
By letter dated October 12, 2023 (Agencywide Documents Access and Management System Accession No. ML23285A092), Virginia Electric and Power Company (Dominion Energy Virginia) submitted Relief Request P-2 to the U.S. Nuclear Regulatory Commission (NRG) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, paragraph (f)(5)(iii), for certain containment spray pumps as part of the Sixth Interval lnservice Testing (/ST) Program at the Surry Power Station (SPS),
Units 1 and 2. With respect to a similar relief request (P-5) for containment spray pumps for the Fifth Interval /ST Program at SPS, Units 1 and 2, Virginia Electric and Power Company had provided a response to an NRG request for additional information in a supplemental letter dated November 5, 2013 (ML13316A006). This additional information does not appear in Relief Request P-2 for containment spray valves for the Sixth Interval
/ST Program.
Regulatory Requirements The NRG regulations in 10 CFR 50.55a(f)(4), lnservice testing standards requirement for operating plants, state, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section /ST (OM Code) must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in paragraph 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The NRG regulations in 10 CFR 50.55a(f)(5), Requirements for updating /ST programs, paragraph (iii), /ST program update: Notification of impractical /ST Code requirements, state:
If the licensee has determined that conformance with certain Code requirements is impractical for its facility, the licensee must notify the Commission and submit, as specified in § 50.4, information to support the determination.
Serial No.24-109 Docket Nos. 50-280/281 Attachment Page 2 of 2 The NRG regulations in 10 CFR 50.55a(f)(6), Actions by the Commission for evaluating impractical and augmented /ST Code requirements, paragraph (i), Impractical /ST requirements: Granting of relief, state:
The Commission will evaluate determinations under paragraph (f)(5) of this section that code requirements are impractical. The Commission may grant relief and may impose such alternative requirements as it determines are authorized by Jaw, will not endanger life or property or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Request for Additional Information
- 1. Section 4, Reason for Request, in Relief Request P-2 in the paragraph titled "Surry Predictive Maintenance Program" states, in part, that for the containment spray pumps, the program employs predictive monitoring techniques, such as vibration monitoring and analysis beyond that required by the ASME OM Code, Subsection ISTB. The licensee is requested to summarize the vibration testing planned for the containment spray pumps as part of this relief request.
Dominion Energy Response The additional vibration testing is performed on the clutch and the motor of the Units 1 and 2 Containment Spray pumps (Mark Nos. 1/2-CS-P-1A and 1/2-CS-P-1 B).
The acceptable range, alert range, and required action range are chosen based on the same criteria that are used for the 1ST points on the component (i.e., in accordance with the Group A Test requirements in OM Code Section ISTB, Table ISTB-5121 -1). The data are reviewed and trended and, if an unusual condition is noted, a Condition Report is generated in the station Corrective Action System to track the necessary corrective actions.
- 2. Section 4, Reason for Request, in Relief Request P-2 in the paragraph titled "Surry Predictive Maintenance Program" states, in part, that for the containment spray pumps, the program employs predictive monitoring techniques, such as oil sampling and analysis. The licensee is requested to specify the frequency of the oil sampling and analysis for the containment spray pumps.
Dominion Energy Response The oil sampling for the Units 1 and 2 Containment Spray pumps 1/2-CS-P-1A and 1/2-CS-P-1 B is performed on a quarterly basis as part of the quarterly pump test. The oil analysis is performed as soon as practical following retrieval of the sample.