ML081980640

Millstone, Units 2/3, North Anna Power, Units 1/2, & Surry Power Station, Units 1/2, Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling (TAC Nos. MD7838, MD7845, MD7846, MD7850, MD7851, MD7884, & MD7885)

ML081980640
Person / Time
Site:	Millstone, Kewaunee, Surry, North Anna
Issue date:	07/23/2008
From:	Melanie Wong NRC/NRR/ADRO/DORL/LPLII-1
To:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
Lingam, Siva NRR/DORL 415-1564
References
GL-08-001, TAC MD7838, TAC MD7845, TAC MD7846, TAC MD7850, TAC MD7851, TAC MD7884, TAC MD7885
Download: ML081980640 (8)

Text

July 23, 2003 Mr. Gerald T. Bischof Vice President Nuclear Engineering Virginia Electric and Power Company Dominion Nuclear Connecticut, Inc.

Dominion Energy Kewaunee, Inc.

Glen Allen, Virginia 23060

SUBJECT:

KEWAUNEE POWER STATION, MILLSTONE POWER STATION, UNITS 2 AND 3, NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, AND SURRY POWER STATION, UNIT NOS. 1 AND 2 - GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, RESPONSE TO EXTENSION REQUEST (TAC NOS. MD7838, MD7845, MD7846, MD7850, MD7851, MD7884 AND MD7885)

Dear Mr. Bischof:

On January 11, 2008, the 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 GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as 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.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

By letter dated May 8, 2008, Dominion Energy Kewaunee, Inc., Dominion Nuclear Connecticut, Inc., and Virginia Electric and Power Company (the licensees), submitted a 3-month response to GL 2008-01 for Kewaunee Power Station (Kewaunee), Millstone Power Station, Units 2 and 3 (Millstone 2 and 3), North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2), and Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2), and proposed alternative actions to the 9-month response date of October 11, 2008, for Millstone 3, North Anna 1 and 2, and Surry 1. The NRC staffs assessment of the response for Millstone 3, North Anna 1 and 2, and Surry 1 is contained in the Enclosure.

The NRC staff reviewed the licensees proposed alternative course of action and concluded that for Millstone 3, North Anna 1 and 2, and Surry 1, with the exception of the clarifications and associated requests discussed in the Enclosure, it is acceptable. This letter allows the licensee to

G. Bischof implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the Enclosure.

This letter does not alter or change the requested 9-month response date of October 11, 2008, for Kewaunee, Millstone 2 and Surry 2.

If you have any questions regarding this issue, please contact Siva P. Lingam, your assigned Project Manager, at 301-415-1564 or, via email, at Siva.Lingam@nrc.gov.

Sincerely,

/RA/

Melanie C. Wong, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-305, 50-336, 50-423, 50-338, 50-339, 50-280 and 50-281

Enclosure:

Assessment of 3-month response cc w/encl: See next page

ML081980640 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/DSS/PGCB/BC NRR/DSS/DD NRR/LPL2-1/BC NAME SLingam MOBrien MMurphy JWermiel MWong DATE 07 / 21 /08 07 / 21 /08 07 / 23 /08 07 / 23 /08 07 / 23 /08 Kewaunee Power Station, Millstone Power Station, Units 2 and 3, North Anna Power Station, Unit Nos. 1 and 2, and Surry Power Station, Unit Nos. 1 & 2 cc:

Mr. David A. Christian President and Chief Nuclear Officer Office of the Attorney General Virginia Electrical and Power Company Commonwealth of Virginia Innsbrook Technical Center 900 East Main Street 5000 Dominion Boulevard Richmond, Virginia 23219 Glen Allen, VA 23060-6711 Mr. Chris L. Funderburk, Director Ms. Lillian M. Cuoco, Esq. Nuclear Licensing & Operations Support Senior Counsel Dominion Resources Services, Inc.

Dominion Resources Services, Inc. Innsbrook Technical Center 120 Tredegar Street, RS-2 5000 Dominion Blvd.

Richmond, VA 23219 Glen Allen, Virginia 23060-6711 Mr. Donald E. Jernigan Mr. C. Lee Lintecum Site Vice President County Administrator Surry Power Station Louisa County Virginia Electric and Power Company Post Office Box 160 5570 Hog Island Road Louisa, Virginia 23093 Surry, Virginia 23883-0315 Old Dominion Electric Cooperative Senior Resident Inspector 4201 Dominion Blvd.

Surry Power Station Glen Allen, Virginia 23060 U. S. Nuclear Regulatory Commission 5850 Hog Island Road Senior Resident Inspector Surry, Virginia 23883 North Anna Power Station U. S. Nuclear Regulatory Commission Chairman P. O. Box 490 Board of Supervisors of Surry County Mineral, Virginia 23117 Surry County Courthouse Surry, Virginia 23683 Mr. Daniel G. Stoddard Site Vice President Dr. W. T. Lough North Anna Power Station Virginia State Corporation Commission Virginia Electric and Power Company Division of Energy Regulation Post Office Box 402 Post Office Box 1197 Mineral, Virginia 23117-0402 Richmond, Virginia 23218 Mr. William R. Matthews Dr. Robert B. Stroube, MD, MPH Senior Vice President, Nuclear Operations State Health Commissioner Virginia Electrical and Power Company Office of the Commissioner Innsbrook Technical Center Virginia Department of Health 5000 Dominion Boulevard Post Office Box 2448 Glen Allen, VA 23060-6711 Richmond, Virginia 23218

Kewaunee Power Station, Millstone Power Station, Units 2 and 3, North Anna Power Station, Unit Nos. 1 and 2, and Surry Power Station, Unit Nos. 1 & 2 cc:

Edward L. Wilds, Jr., Ph.D. Mr. Joseph Roy Director, Division of Radiation Director of Operations Department of Environmental Massachusetts Municipal Wholesale Protection Electric Company 79 Elm Street P.O. Box 426 Hartford, CT 06106-5127 Ludlow, MA 01056 Regional Administrator, Region I Mr. William D. Bartron U.S. Nuclear Regulatory Commission Licensing Supervisor 475 Allendale Road Dominion Nuclear Connecticut, Inc.

King of Prussia, PA 19406 Building 475, 5th Floor Roper Ferry Road First Selectmen Waterford, CT 06385 Town of Waterford 15 Rope Ferry Road Mr. J. Alan Price Waterford, CT 06385 Site Vice President Dominion Nuclear Connecticut, Inc.

Charles Brinkman, Director Building 475, 5th Floor Washington Operations Nuclear Services Rope Ferry Road Westinghouse Electric Company Waterford, CT 06385 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852 Ms. Leslie N. Hartz Dominion Energy Kewaunee, Inc.

Senior Resident Inspector Kewaunee Power Station Millstone Power Station N 490 Highway 42 c/o U.S. Nuclear Regulatory Commission Kewaunee, WI 54216 P. O. Box 513 Niantic, CT 06357 Resident Inspectors Office U. S. Nuclear Regulatory Commission Mr. J. W. "Bill" Sheehan N490 Highway 42 Co-Chair NEAC Kewaunee, WI 54216-9510 19 Laurel Crest Drive Waterford, CT 06385 Mr. Thomas L. Breene Dominion Energy Kewaunee, Inc.

Ms. Nancy Burton Kewaunee Power Station 147 Cross Highway N490 Highway 42 Redding Ridge, CT 00870 Kewaunee, WI 54216 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terrys Plain Road Simsbury, CT 06070

ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 KEWAUNEE POWER STATION, MILLSTONE POWER STATION, UNITS 2 AND 3, NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, AND SURRY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-305, 50-336, 50-423, 50-338, 50-339, 50-280, AND 50-281

1.0 Background

On January 11, 2008, the 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 GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as 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.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2.0 Licensees Proposed Alternative Course of Action By letter dated May 8, 2008 (ADAMS Accession No. ML081300282), Dominion Energy Kewaunee, Inc., Dominion Nuclear Connecticut, Inc., and Virginia Electric and Power Company (the licensees), submitted a 3-month response to GL 2008-01 for Kewaunee Power Station (Kewaunee), Millstone Power Station, Units 2 and 3 (Millstone 2 and 3), North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2), and Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and Enclosure

2), and proposed alternative actions to the 9-month response date of October 11, 2008, for Millstone 3, North Anna 1 and 2, and Surry 1. The licensees indicate that they will provide a 9-month response to GL 2008-01, consistent with the GLs requested schedule by October 11, 2008, that will address the required aspects of the GL for Millstone 3, North Anna 1 and 2, and Surry 1. This letter does not alter or change the requested 9-month response date of October 11, 2008, for Kewaunee, Millstone 2 and Surry 2. However, the licensees request additional time after completion of the confirmatory walkdown in the following scheduled refueling outages to submit supplemental response for Millstone 3, North Anna 1 and 2, and Surry 1:

Millstone 3 fall 2008 North Anna 2 fall 2008 North Anna 1 spring 2009 Surry 1 spring 2009 As an alternative course of action, the licensees provide the following commitments for completion of the GL response for Millstone 3, North Anna 1 and 2, and Surry 1:

1. Provide a supplemental response to GL 2008-01 by January 15, 2009, for Millstone 3 and North Anna 2.

2. Provide a supplemental response to GL 2008-01 by July 15, 2009, for North Anna 1 and Surry 1.

3.0 NRC staff Assessment The NRC staff finds that for Millstone 3, North Anna 1 and 2, and Surry 1, with the exception of the clarifications and associated requests discussed below, the licensees proposed alternative course of action is acceptable.

The NRC staff notes that the licensees May 8, 2008, response does not clearly describe the content to be provided in its 9-month submittals. The NRC staff requests that the licensee submit the information requested in the GL as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the refueling outages in accordance with the schedule listed in Section 2.0 of this evaluation for Millstone 3, North Anna 1 and 2, and Surry 1, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC by January 15, 2009, for Millstone 3 and North Anna 2, and July 15, 2009, for North Anna 1 and Surry 1.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions,

and the basis for that schedule.

The NRC staff noted that the licensees submittal dated May 8, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suction piping, as well as, whether analysis development is needed to assess gas transport in the subject system piping as a function of system flow. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensees address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensees responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

Date: July 23, 2008