ML081430612

Units 1 & 2 - NRC Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-water Reactors Request for Interim.

ML081430612
Person / Time
Site:	Millstone, Kewaunee, Surry, North Anna
Issue date:	05/22/2008
From:	Gerald Bichof Dominion, Dominion Nuclear Connecticut, Dominion Resources Services, Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
08-0275A, NL&OS/GDM R0
Download: ML081430612 (5)

Text

Dominion Resources Services, Inc.

~I)OO Dominion Boulevard, Glen Allen, VA 2,\0(,()

\\'ch Address: www.dom.com May 22, 2008 U.S. Nuclear Regulatory Commission Serial No. 08-0275A Attention: Document Control Desk NL&OS/GDM RO One White Flint North Docket Nos. 50-305 11555 Rockville Pike 50-336/423 Rockville, MD 20852-2738 50-338/339 50-280/281 License Nos. DPR-43 DPR-65/NPF-49 NPF-4/7 DPR-32/37 DOMINION ENERGY KEWAUNE:E. INC. (DEK)

DOMINION NUCLEAR CONNECTICUT. INC. (DNC)

VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

KEWAUNEE POWER STATION MILLSTONE POWER STATION UNITS 2 AND 3 NORTH ANNA AND SURRY PO'NER STATION UNITS 1 AND 2 NRC GENERIC LETTER (GL) 2004-02. POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY F~ECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED-WATER REACTORS REQUEST FOR INTERIM EXTENSION OF COMPLETION DATES FOR CORRECTIVE ACTIONS In a letter dated November 15, 2007 (Serial No. 07-0660), DEK, DNC and Dominion submitted schedule extension requests for Kewaunee, Millstone Units 2 and 3, North Anna Units 1 and 2 and Surry Units 1 and 2 to extend the completion date for corrective actions associated with GL 2004-02. The request was primarily for the completion of downstream effects evaluations and chemical effects testing and evaluation. The requested extension dates were June 30, 2008 for Kewaunee and November 30, 2008 for Millstone, North Anna and Surry.

In a letter dated December 13, 2007, the NRC granted DEK, DNC and Dominion an extension to May 31, 2008 for each plant citing the importance of prompt closure of GL 2004-02 and the potential for schedule improvement.

Considerable effort and resources have been expended to complete the outstanding corrective actions for each station by the approved extension date, and significant progress has been made towards the resolution of the remaining GSI-191 issues. However, it has become evident that all of the remaining corrective actions cannot be completed by May 31, 2008. In a letter dated

Serial Number 08-0275A Docket Nos. 50-305/336/423/338/339/280/281 GL 2004-02; Request for Extensions Page 2 of 5 May 21, 2008 (Serial No. 08-0:275), DEK, DNC and Dominion requested an extension until September 30, :2008 to complete the GL 2004-02 corrective actions for Kewaunee, Millstone Units 2 and 3, North Anna Units 1 and 2, and Surry Units 1 and 2. The requested extension period is to complete the remaining chemical effects testing and evaluation and downstream effects analyses.

In order to support NRC review of the May 21, 2008 extension request and the accompanying detailed justifications, we request approval of an interim schedule extension until June 30, 2008. The interim extension request is supported by the previous extension request bases included in the November 15, 2007 letter, which addressed the three criteria contained in SECY-06-0078 dated March 31, 2006, "Criteria for Evaluating Delay of Hardware Changes," and the applicable elements of the NRC justification for continued operation in the "Summary of July 26-27, 2001 Meeting with Nuclear Energy Institute and Industry on ECCS Strainer Blockage in PWRs," dated August 14, 2001 for each plant. The bases included in the November 15, 2007 letter remain valid and applicable for this interim, short-term extension request and continue to confirm, that Kewaunee, Millstone Units 2 and 3, North Anna Units 1 and 2, and Surry Units 1 and 2 will continue to meet their current plant licensing bases regarding the function and operability of the containment sumps during the period of the requested extensions in that:

• The plants have completed considerable physical and analytical activities to provide a high level of Emergency Core Cooling System (ECCS) and Recirculation Spray (RS) System (as applicable) performance including replacing the ECCS and RS strainers,

• The plants have implemented mitigative measures to minimize the risk of degraded ECCS and RS (as applicable) functions during the extension period, and

• The plants have plant-specilfic plans with milestones and schedules to address the outstanding technical issues with sufficient conservatism to address uncertainties.

Finally, even though a detailed, quantitative risk assessment is not required for short-term extension requests, the plant risk evaluations provided in our November 15, 2007 letter determined that the risk was "small" and bound the risk associated with the interim extension period requested herein.

Therefore, DEK, DNC and Dominion have established that there is reasonable assurance during this requested interim period that Kewaunee, Millstone Units 2

Serial Number 08-0275A Docket Nos. 50-305/336/423/338/339/280/281 GL 2004-02; Request for Extensions Page 3 of 5 and 3, North Anna Units 1 and 2, and Surry Units 1 and 2 will provide acceptable strainer function with adequate margin for uncertainties, as confirmed in the NRC's December 13, 2007 letter.

If you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Sincerely, Gerald T. Bischof Vice President - Nuclear Engineering Commitments made in this correspondence: None.

COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President -

Nuclear Engineering of Dominion Energy Kewaunee, Inc., Dominion Nuclear Connecticut, Inc. and Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of those companies, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this ~ay of ~ , 2008.

My Commission Expires:  :.5--3/ - 10 .

VICKI L. HULL Notary Public

~

~.O:~/LL Notary Public Commonwealth of VIrginia l 1~2 IllY CommlUlon Explrel May 11.2010

Serial Number 08-0275A Docket Nos. 50-305/336/423/338/339/280/281 GL 2004-02; Request for Extensions Page 4 of 5 cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406-1415 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 U.S. Nuclear Regulatory Commission Region III 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 NRC Senior Resident Inspector Kewaunee Power Station NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station Ms. M. H. Chernoff NRC Project Manager - Kewaunee U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 H4A 11555 Rockville Pike Rockville, Maryland 20852*-2738

Serial Number 08-0275A Docket Nos. 50-305/336/423/338/339/280/281 GL 2004-02; Request for Extensions Page 5 of 5 Mr. J. D. Hughey NRC Project Manager - Millstone Units 2 and 3 U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 83 11555 Rockville Pike Rockville, MD 20852-2738 cc: (continued)

Mr. S. P. Lingam NRC Project Manager - Surry and North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 G9A 11555 Rockville Pike Rockville, Maryland 2085~~