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| issue date = 05/23/2011
| issue date = 05/23/2011
| title = Closeout of Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling Decay Heat Removal, and Containment Spray Systems.
| title = Closeout of Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling Decay Heat Removal, and Containment Spray Systems.
| author name = Wiebe J S
| author name = Wiebe J
| author affiliation = NRC/NRR/DORL/LPLII-1
| author affiliation = NRC/NRR/DORL/LPLII-1
| addressee name = Heacock D A
| addressee name = Heacock D
| addressee affiliation = Virginia Electric & Power Co (VEPCO)
| addressee affiliation = Virginia Electric & Power Co (VEPCO)
| docket = 05000338, 05000339
| docket = 05000338, 05000339
| license number = NPF-004, NPF-007
| license number = NPF-004, NPF-007
| contact person = Wiebe J S
| contact person = Wiebe J
| case reference number = TAC MD7850, TAC MD7851, GL-08-001
| case reference number = TAC MD7850, TAC MD7851, GL-08-001
| document type = Letter
| document type = Letter
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 May 23.2011 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 NORTH ANNA POWER STATION. UNIT NOS. 1 AND 2, CLOSEOUT OF GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" (TAC NOS. MD7850 AND MD7851)  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 23.2011 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
 
==SUBJECT:==
NORTH ANNA POWER STATION. UNIT NOS. 1 AND 2, CLOSEOUT OF GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" (TAC NOS. MD7850 AND MD7851)


==Dear Mr. Heacock:==
==Dear Mr. Heacock:==
On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling. Decay Heat Removal, and Containment Spray Systems" (Agencywide Documents Access and Management System (ADAMS). Accession No. ML07291 0759). The stated purpose of GL 2008-01 was (a) to request addressees to submit information to demonstrate that the subject systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational.
 
and testing control measures are in place for maintaining this compliance; and (b) to collect the requested information to determine if additional regulatory action is required.
On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling. Decay Heat Removal, and Containment Spray Systems" (Agencywide Documents Access and Management System (ADAMS). Accession No. ML072910759). The stated purpose of GL 2008-01 was (a) to request addressees to submit information to demonstrate that the subject systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational. and testing control measures are in place for maintaining this compliance; and (b) to collect the requested information to determine if additional regulatory action is required.
By letters dated October 14. 2008 (ADAMS Accession No. ML082890094). January 15, 2009 (ADAMS Accession No. ML090150579), July 6, 2009 (ADAMS Accession No. ML091880506), and July 29,2010 (ADAMS Accession No. ML 102180020), Virginia Electric and Power Company (VEPCO, the licensee).
By letters dated October 14. 2008 (ADAMS Accession No. ML082890094). January 15, 2009 (ADAMS Accession No. ML090150579), July 6, 2009 (ADAMS Accession No. ML091880506),
provided responses to GL 2008-01. The NRC staff has completed its review of the GL. As described in the enclosure, the NRC staff concludes that the subject systems are currently operable and the licensee has acceptably demonstrated "that gas accumUlation is maintained less than the amount that challenges operability of these systems. and that appropriate action is taken when conditions adverse to quality are identified," as stated in GL 2008-01. The NRC staff is continuing to engage with stakeholders regarding the creation of durable guidance for Gas Management which may require additional actions by the licensee beyond the scope of GL 2008-01. An inspection.
and July 29,2010 (ADAMS Accession No. ML102180020), Virginia Electric and Power Company (VEPCO, the licensee). provided responses to GL 2008-01.
using Temporary Instruction (TI) 2515/177. "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal. and Containment Spray Systems (NRC Generic Letter 2008-01)" (ADAMS Accession No. ML082950666) may be performed by the NRC's Region II staff. TI2515/177 is confirmatory in nature in that it directs NRC inspectors to selectively verify that the licensee has implemented or is in the process of acceptably implementing the commitments, modifications.
The NRC staff has completed its review of the GL. As described in the enclosure, the NRC staff concludes that the subject systems are currently operable and the licensee has acceptably demonstrated "that gas accumUlation is maintained less than the amount that challenges operability of these systems. and that appropriate action is taken when conditions adverse to quality are identified," as stated in GL 2008-01. The NRC staff is continuing to engage with stakeholders regarding the creation of durable guidance for Gas Management which may require additional actions by the licensee beyond the scope of GL 2008-01. An inspection. using Temporary Instruction (TI) 2515/177. "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal. and Containment Spray Systems (NRC Generic Letter 2008-01)" (ADAMS Accession No. ML082950666) may be performed by the NRC's Region II staff. TI2515/177 is confirmatory in nature in that it directs NRC inspectors to selectively verify that the licensee has implemented or is in the process of acceptably implementing the commitments, modifications.
and programmatically controlled actions described in the licensee's response to GL 2008-01 and the plant-specific information supports a conclusion that subject systems operability is reasonably ensured.
and programmatically controlled actions described in the licensee's response to GL 2008-01 and the plant-specific information supports a conclusion that subject systems operability is reasonably ensured.
D. Heacock If you have any questions regarding this letter, please feel free to contact me at (301) 415-6606.
 
Sincerely, oel S. Wiebe, Senior Project Manager lant Licensing Branch Division of Operating Reactor Office of Nuclear Reactor Docket Nos. 50-338 and Review of GL cc w/encl: Distribution via REVIEW BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF RESPONSE TO GENERIC LETTER 2008-01 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-338 AND 50-339 On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759).
D. Heacock                                     -2 If you have any questions regarding this letter, please feel free to contact me at (301) 415-6606.
The stated purpose of GL 2008-01 was (a) to request addressees to submit information to demonstrate that the subject systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design. operational, and testing control measures are in place for maintaining this compliance; and, (b) to collect the requested information to determine if additional regulatory action is required.
Sincerely,
GL 2008-01 requested that licensees provide the following information within 9 months of the date of the GL: A description of the results of evaluations that were performed pursuant to requested actions specified in the GL. This description should provide sufficient information to demonstrate that you are or will be in compliance with the quality assurance criteria in Sections III. V, XI, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license as those requirements apply to the subject systems; A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations; and, A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
                                                  ~tJ~
oel S. Wiebe, Senior Project Manager lant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339
 
==Enclosure:==
 
Review of GL 2008-01 cc w/encl: Distribution via Listserv
 
REVIEW BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF RESPONSE TO GENERIC LETTER 2008-01 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-338 AND 50-339 On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The stated purpose of GL 2008-01 was (a) to request addressees to submit information to demonstrate that the subject systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design. operational, and testing control measures are in place for maintaining this compliance; and, (b) to collect the requested information to determine if additional regulatory action is required.
GL 2008-01 requested that licensees provide the following information within 9 months of the date of the GL:
(a)    A description of the results of evaluations that were performed pursuant to requested actions specified in the GL. This description should provide sufficient information to demonstrate that you are or will be in compliance with the quality assurance criteria in Sections III. V, XI, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license as those requirements apply to the subject systems; (b)    A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations; and, (c)    A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
By letters dated October 14,2008 (ADAMS Accession No. ML082890094), January 15, 2009 ADAMS Accession No. ML090150579), July 6,2009 (ADAMS Accession No. ML091880506).
By letters dated October 14,2008 (ADAMS Accession No. ML082890094), January 15, 2009 ADAMS Accession No. ML090150579), July 6,2009 (ADAMS Accession No. ML091880506).
and July 29,2010 (ADAMS Accession No. ML 102180020).
and July 29,2010 (ADAMS Accession No. ML102180020). Virginia Electric and Power Company (VEPCO, the licensee). provided responses to GL 2008-01. During the review, the NRC staff determined that additional information was needed.
Virginia Electric and Power Company (VEPCO, the licensee).
Enclosure
provided responses to GL 2008-01. During the review, the NRC staff determined that additional information was needed. Enclosure
 
-2 Request for additional information No.1 (RAI 1) requested a regulatory commitment and schedule for applying the Technical Specification Task Force (TSTF) process to any Technical Specification (TS) changes resulting from GL 2008-01. VEPCO provided a commitment to evaluate the NRC-approved TSTF and to submit a license amendment(s) if determined necessary within 1 year of NRC approval.
                                                -2 Request for additional information No.1 (RAI 1) requested a regulatory commitment and schedule for applying the Technical Specification Task Force (TSTF) process to any Technical Specification (TS) changes resulting from GL 2008-01. VEPCO provided a commitment to evaluate the NRC-approved TSTF and to submit a license amendment(s) if determined necessary within 1 year of NRC approval. The NRC staff concludes that this acceptably addresses the request.
The NRC staff concludes that this acceptably addresses the request. RAI 2 addressed surveillance criteria, methods, and locations.
RAI 2 addressed surveillance criteria, methods, and locations. The licensee stated that periodic venting is not performed on the recirculation spray, quench spray, and residual heat removal systems because they are not susceptible to gas accumulation. These systems are procedurally filled and vented prior to return to service after maintenance. The licensee periodically vents locations in the high-head safety injection and low-head safety injection (LHSI) piping outside of containment. The licensee states that if gas is found while venting, the procedure will be stopped and the void analyzed. Several methods may be used to analyze the void including ultrasonic testing (UT). a rotometer. and chemical analysis. The NRC staff concludes that this is responsive to the GL RAI 3 addressed surveillance intervals. The licensee performs full flow testing and system flow sweeping each refueling outage. Static venting is performed every 92 days in accordance with the North Anna TS. The licensee stated that there is no appreciable gas build up in the trending of the volume of gas found when venting and that this favorable operating experience justifies the 92-day interval. The NRC staff concludes that this is responsive to the GL RAI4 addressed the "alternate monitoring methodology" mentioned in the licensee's October 14, 2008, response. Additional monitoring activities include back leakage testing of Safety Injection (SI) check valves, thermal relief valve lift and LHSI pump discharge pressure during quarterly testing, LHSI discharge header temperature monitoring, and refueling water storage tank in-leakage monitoring. The licensee stated that these alternate monitoring methodologies are being used at North Anna because a significant portion of the piping is inside containment and it is impractical to monitor for gas using traditional means of UT inspection or high point venting. The NRC staff concludes that this acceptably addresses the request.
The licensee stated that periodic venting is not performed on the recirculation spray, quench spray, and residual heat removal systems because they are not susceptible to gas accumulation.
RAI 5 addresses training associated with gas accumulation and management. The licensee is participating in the industry Gas Accumulation Team initiatives. They have received the Institute of Nuclear Power Operations training modules on gas accumUlation and management and plan to incorporate them into their training programs. The NRC staff concludes that this acceptably addresses the request and the approach is acceptable.
These systems are procedurally filled and vented prior to return to service after maintenance.
The licensee periodically vents locations in the high-head safety injection and low-head safety injection (LHSI) piping outside of containment.
The licensee states that if gas is found while venting, the procedure will be stopped and the void analyzed.
Several methods may be used to analyze the void including ultrasonic testing (UT). a rotometer.
and chemical analysis.
The NRC staff concludes that this is responsive to the GL RAI 3 addressed surveillance intervals.
The licensee performs full flow testing and system flow sweeping each refueling outage. Static venting is performed every 92 days in accordance with the North Anna TS. The licensee stated that there is no appreciable gas build up in the trending of the volume of gas found when venting and that this favorable operating experience justifies the 92-day interval.
The NRC staff concludes that this is responsive to the GL RAI4 addressed the "alternate monitoring methodology" mentioned in the licensee's October 14, 2008, response.
Additional monitoring activities include back leakage testing of Safety Injection (SI) check valves, thermal relief valve lift and LHSI pump discharge pressure during quarterly testing, LHSI discharge header temperature monitoring, and refueling water storage tank in-leakage monitoring.
The licensee stated that these alternate monitoring methodologies are being used at North Anna because a significant portion of the piping is inside containment and it is impractical to monitor for gas using traditional means of UT inspection or high point venting. The NRC staff concludes that this acceptably addresses the request. RAI 5 addresses training associated with gas accumulation and management.
The licensee is participating in the industry Gas Accumulation Team initiatives.
They have received the Institute of Nuclear Power Operations training modules on gas accumUlation and management and plan to incorporate them into their training programs.
The NRC staff concludes that this acceptably addresses the request and the approach is acceptable.
Based on the responses to the GL and the RAls, the NRC staff concluded that the licensee has acceptably demonstrated "that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified," as stated in GL 2008-01.
Based on the responses to the GL and the RAls, the NRC staff concluded that the licensee has acceptably demonstrated "that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified," as stated in GL 2008-01.
D. Heacock -If you have any questions regarding this letter, please feel free to contact me at (301) 415-6606.
 
Sincerely, IRA! Joel S. Wiebe, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation . Docket Nos. 50-338 and 50-339 Review of GL cc w/encl: Distribution via Listserv DISTRIBUTION:
D. Heacock                                       - 2 If you have any questions regarding this letter, please feel free to contact me at (301) 415-6606.
Public RidsNrrLAMO'Brien Resource LPL2-1 R/F RidsOgcRp Resouce RidsNrrLpl2-1 Resource RidsNrrDssSrxb Resource RidsRgn2MailCenter Resource RidsAcrsAcnw_MailCTR Resource RidsNrrDorlDpr Resource JGall, NRR RidsNrrPMNorthAnna Resource AUlses, NRR a e ADAMS A ccesslon N o. ML11125A007 "b)v memo d t d 4/8/11 OFFICIAL RECORD COpy OFFICE NAME DATE --C;..... NRRlLPL2-1/PM JWiebe 05/19/11 NRR/LPL2-1/LA MO'Brien (SUttle for) 05/18/11 NRR/DSS/SRXB AUlses" 418/11 NRRlLPL2-1/BC GKulesa 05123/11 NRR/LPL2-1/PM JWiebe 05/23/11}}
Sincerely, IRA!
Joel S. Wiebe, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
. Docket Nos. 50-338 and 50-339
 
==Enclosure:==
 
Review of GL 2008-01 cc w/encl: Distribution via Listserv DISTRIBUTION:
Public                         RidsNrrLAMO'Brien Resource               LPL2-1 R/F RidsOgcRp Resouce               RidsNrrLpl2-1 Resource                   RidsNrrDssSrxb Resource RidsRgn2MailCenter Resource     RidsAcrsAcnw_MailCTR Resource             RidsNrrDorlDpr Resource JGall, NRR                     RidsNrrPMNorthAnna Resource               AUlses, NRR ADAMS A ccesslon No. ML11125A007                                 "b)v memo d ated 4/8/11 OFFICE NRRlLPL2-1/PM     NRR/LPL2-1/LA      NRR/DSS/SRXB NRRlLPL2-1/BC            NRR/LPL2-1/PM NAME    JWiebe            MO'Brien           AUlses"          GKulesa            JWiebe (SUttle for)
DATE
  --C;.....
05/19/11         05/18/11                418/11       05123/11           05/23/11 OFFICIAL RECORD COpy}}

Latest revision as of 00:06, 13 November 2019

Closeout of Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling Decay Heat Removal, and Containment Spray Systems.
ML11125A007
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 05/23/2011
From: Joel Wiebe
Plant Licensing Branch II
To: Heacock D
Virginia Electric & Power Co (VEPCO)
Wiebe J
References
TAC MD7850, TAC MD7851, GL-08-001
Download: ML11125A007 (5)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 23.2011 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION. UNIT NOS. 1 AND 2, CLOSEOUT OF GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" (TAC NOS. MD7850 AND MD7851)

Dear Mr. Heacock:

On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling. Decay Heat Removal, and Containment Spray Systems" (Agencywide Documents Access and Management System (ADAMS). Accession No. ML072910759). The stated purpose of GL 2008-01 was (a) to request addressees to submit information to demonstrate that the subject systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational. and testing control measures are in place for maintaining this compliance; and (b) to collect the requested information to determine if additional regulatory action is required.

By letters dated October 14. 2008 (ADAMS Accession No. ML082890094). January 15, 2009 (ADAMS Accession No. ML090150579), July 6, 2009 (ADAMS Accession No. ML091880506),

and July 29,2010 (ADAMS Accession No. ML102180020), Virginia Electric and Power Company (VEPCO, the licensee). provided responses to GL 2008-01.

The NRC staff has completed its review of the GL. As described in the enclosure, the NRC staff concludes that the subject systems are currently operable and the licensee has acceptably demonstrated "that gas accumUlation is maintained less than the amount that challenges operability of these systems. and that appropriate action is taken when conditions adverse to quality are identified," as stated in GL 2008-01. The NRC staff is continuing to engage with stakeholders regarding the creation of durable guidance for Gas Management which may require additional actions by the licensee beyond the scope of GL 2008-01. An inspection. using Temporary Instruction (TI) 2515/177. "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal. and Containment Spray Systems (NRC Generic Letter 2008-01)" (ADAMS Accession No. ML082950666) may be performed by the NRC's Region II staff. TI2515/177 is confirmatory in nature in that it directs NRC inspectors to selectively verify that the licensee has implemented or is in the process of acceptably implementing the commitments, modifications.

and programmatically controlled actions described in the licensee's response to GL 2008-01 and the plant-specific information supports a conclusion that subject systems operability is reasonably ensured.

D. Heacock -2 If you have any questions regarding this letter, please feel free to contact me at (301) 415-6606.

Sincerely,

~tJ~

oel S. Wiebe, Senior Project Manager lant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosure:

Review of GL 2008-01 cc w/encl: Distribution via Listserv

REVIEW BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF RESPONSE TO GENERIC LETTER 2008-01 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-338 AND 50-339 On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The stated purpose of GL 2008-01 was (a) to request addressees to submit information to demonstrate that the subject systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design. operational, and testing control measures are in place for maintaining this compliance; and, (b) to collect the requested information to determine if additional regulatory action is required.

GL 2008-01 requested that licensees provide the following information within 9 months of the date of the GL:

(a) A description of the results of evaluations that were performed pursuant to requested actions specified in the GL. This description should provide sufficient information to demonstrate that you are or will be in compliance with the quality assurance criteria in Sections III. V, XI, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license as those requirements apply to the subject systems; (b) A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations; and, (c) A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

By letters dated October 14,2008 (ADAMS Accession No. ML082890094), January 15, 2009 ADAMS Accession No. ML090150579), July 6,2009 (ADAMS Accession No. ML091880506).

and July 29,2010 (ADAMS Accession No. ML102180020). Virginia Electric and Power Company (VEPCO, the licensee). provided responses to GL 2008-01. During the review, the NRC staff determined that additional information was needed.

Enclosure

-2 Request for additional information No.1 (RAI 1) requested a regulatory commitment and schedule for applying the Technical Specification Task Force (TSTF) process to any Technical Specification (TS) changes resulting from GL 2008-01. VEPCO provided a commitment to evaluate the NRC-approved TSTF and to submit a license amendment(s) if determined necessary within 1 year of NRC approval. The NRC staff concludes that this acceptably addresses the request.

RAI 2 addressed surveillance criteria, methods, and locations. The licensee stated that periodic venting is not performed on the recirculation spray, quench spray, and residual heat removal systems because they are not susceptible to gas accumulation. These systems are procedurally filled and vented prior to return to service after maintenance. The licensee periodically vents locations in the high-head safety injection and low-head safety injection (LHSI) piping outside of containment. The licensee states that if gas is found while venting, the procedure will be stopped and the void analyzed. Several methods may be used to analyze the void including ultrasonic testing (UT). a rotometer. and chemical analysis. The NRC staff concludes that this is responsive to the GL RAI 3 addressed surveillance intervals. The licensee performs full flow testing and system flow sweeping each refueling outage. Static venting is performed every 92 days in accordance with the North Anna TS. The licensee stated that there is no appreciable gas build up in the trending of the volume of gas found when venting and that this favorable operating experience justifies the 92-day interval. The NRC staff concludes that this is responsive to the GL RAI4 addressed the "alternate monitoring methodology" mentioned in the licensee's October 14, 2008, response. Additional monitoring activities include back leakage testing of Safety Injection (SI) check valves, thermal relief valve lift and LHSI pump discharge pressure during quarterly testing, LHSI discharge header temperature monitoring, and refueling water storage tank in-leakage monitoring. The licensee stated that these alternate monitoring methodologies are being used at North Anna because a significant portion of the piping is inside containment and it is impractical to monitor for gas using traditional means of UT inspection or high point venting. The NRC staff concludes that this acceptably addresses the request.

RAI 5 addresses training associated with gas accumulation and management. The licensee is participating in the industry Gas Accumulation Team initiatives. They have received the Institute of Nuclear Power Operations training modules on gas accumUlation and management and plan to incorporate them into their training programs. The NRC staff concludes that this acceptably addresses the request and the approach is acceptable.

Based on the responses to the GL and the RAls, the NRC staff concluded that the licensee has acceptably demonstrated "that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified," as stated in GL 2008-01.

D. Heacock - 2 If you have any questions regarding this letter, please feel free to contact me at (301) 415-6606.

Sincerely, IRA!

Joel S. Wiebe, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

. Docket Nos. 50-338 and 50-339

Enclosure:

Review of GL 2008-01 cc w/encl: Distribution via Listserv DISTRIBUTION:

Public RidsNrrLAMO'Brien Resource LPL2-1 R/F RidsOgcRp Resouce RidsNrrLpl2-1 Resource RidsNrrDssSrxb Resource RidsRgn2MailCenter Resource RidsAcrsAcnw_MailCTR Resource RidsNrrDorlDpr Resource JGall, NRR RidsNrrPMNorthAnna Resource AUlses, NRR ADAMS A ccesslon No. ML11125A007 "b)v memo d ated 4/8/11 OFFICE NRRlLPL2-1/PM NRR/LPL2-1/LA NRR/DSS/SRXB NRRlLPL2-1/BC NRR/LPL2-1/PM NAME JWiebe MO'Brien AUlses" GKulesa JWiebe (SUttle for)

DATE

--C;.....

05/19/11 05/18/11 418/11 05123/11 05/23/11 OFFICIAL RECORD COpy

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