ML14094A008

Surry, Units 1 and 2, Annual Changes, Test and Experiments Report, Regulatory Commitment Evaluation Report

ML14094A008
Person / Time
Site:	Surry
Issue date:	03/31/2014
From:	Lawrence D C Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-113
Download: ML14094A008 (5)

Text

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261March 31, 2014U.S. Nuclear Regulatory Commission Serial No. 14-113Attn: Document Control Desk SPS/JSA:

R1Washington, DC 20555-0001 Docket Nos. 50-28050-281License Nos. DPR-32DPR-37Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNITS 1 AND 2ANNUAL CHANGES.

TESTS, AND EXPERIMENTS REPORTREGULATORY COMMITMENT EVALUATION REPORTVirginia Electric and Power Company submits the annual report of Changes, Tests, andExperiments pursuant to 10 CFR 50.59(d)(2) and Regulatory Commitment Changesidentified in Commitment Evaluation Summaries implemented at Surry Power Stationduring 2013. Attachment 1 provides a description and summary of the Regulatory Evaluations and Regulatory Commitment Changes in 2013.Should you have any questions regarding this report, please do not hesitate to contact meat (757) 365-2003.

Ve$I yourDou as nce,Director ation Safety & Licensing Surry Power StationAttachment Commitments made in this letter: None.cc: United States Nuclear Regulatory Commission, Region IIMarquis One Tower, Suite 1200245 Peachtree Center Avenue, NEAtlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station --- _"-L- --

Serial No. 14-11310 CFR 50.59 ReportPage 1 of 4Attachment 1Surry Units 1 & 22013 -10 CFR 50.59 Changes, Tests and Experiments13-001 Regulatory Evaluation 02/12/13Description:

Regulatory Evaluation 13-001 reviewed a design change for the installation ofa temporary Service Water (SW) flow path jumper to the Component Cooling HeatExchangers (CCHX) to allow inspection and repair of the existing SW supply to theCCHXs.Summary:

The temporary SW jumper to the CCHXs must be provided to maintainadequate cooling for operation of Unit 2 and cooling residual heat from Unit 1 and thespent fuel pool. This evaluation provided documentation for the design change to installthe temporary SW flow path jumper to the CCHXs and included installing a spool piece,SW inlet valve, and the SW jumper piping during the non-outage phase of the project.

Thefinal connection and placing the SW jumper in operation will be completed during theoutage. The review determined the SW and CC water systems' design functions andbasic configurations are not being altered as a result of using the temporary flow path.However, since the SW jumper is safety related and seismic but not missile protected overthe entire length, the design change was contingent on NRC approval prior to placing thejumper in service.

A Technical Specification (TS) and TS Basis change was submitted tothe NRC to implement the jumper, defeat the automatic closure of the SW isolation valves,and place two channels of the intake canal level instrumentation in trip.

Serial No. 14-11310 CFR 50.59 ReportPage 2 of 4Attachment ISurry Units 1 & 22013 -10 CFR 50.59 Changes, Tests and Experiments12-003, Rev. 2 Regulatory Evaluation 05/09/13Description:

Regulatory Evaluation 12-003, Rev. 2 reviewed the functionality of a HI-HIConsequence Limiting Safeguards (CLS) relay with a non-functional unlatch coil. Revision2 documented having an electrician on site to locally unlatch the Unit 1 Train B HI-HI CLSrelay.Summary:

The Unit 1 Train B HI-HI CLS relay is energized and latched from automatic signals to initiate the HI-HI CLS functions.

The unlatching of the relay is normally donemanually from a pushbutton in the Main Control Room (MCR). The unlatch coil in the relayis not functional and will not unlatch the relay from the MCR pushbutton.

Testing hasdemonstrated the relay can be consistently and safely unlatched locally at the relay. Anoperability determination was developed to document the acceptability of the use of localreset. Revision 2 of Regulatory Evaluation 12-003 requires an electrician, briefed on theperformance of manually resetting the HI-HI CLS relay, to be available while the non-functional unlatch coil condition exists. Operations procedures have been revised to directrequired electrical maintenance personnel to the main control room following a HI-HI CLSand to locally unlatch the HI-HI CLS relay as directed by Operations when HI-HI CLS canbe reset based on Containment conditions.

Additionally, applicable Operations procedures direct Operators to stop the Containment Spray Pumps if CLS cannot be locally reset.The safety related function of the relay as described in the UFSAR is to automatically initiate HI-HI CLS. This accident mitigation function is not adversely affected by thechange in the CLS manual reset function.

The HI-HI CLS function is an accident mitigation function and is not an accident initiator.

There are no accidents associated with actual orinadvertent actuation of CLS. The initiation of HI-HI CLS and the subsequent automatic actions are not affected by changing the location of the HI-HI CLS reset function.

Therefore, HI-HI-CLS system will function as required to mitigate any credited accidents.

This change only affects the ability to reset HI-HI CLS. Therefore, the operability determination could be implemented without prior NRC review and approval.

Serial No. 14-11310 CFR 50.59 ReportPage 3 of 4Attachment 1Surry Units 1 & 22013 -10 CFR 50.59 Changes, Tests and Experiments13-002 Regulatory Evaluation 07/11/13Description:

Regulatory Evaluation 13-002 reviewed the implementation of a revisedControl Rod Ejection Accident analysis for Surry.Summary:

The Control Rod Ejection Accident analysis for Surry Power Station wasrevised to rectify the error found in the accounting of bypass flow in the models used forthe analysis and updated the pre-ejection FQ value. The results of the revised analysisare closer to the UFSAR specified acceptance criteria than the previous analysis.

However, the UFSAR described aceptance criteria continues to be met.The evaluation determined that the revised analysis resulted in no more than a minimalincrease in the frequency of occurrence of an accident previously evaluated in the SAR, nomalfunction of a structure, system, or component (SSC) important to safety, no increase inthe consequences of a malfunction of a SSC important to safety previously evaluated inthe SAR or with a different result than previously

analyzed, and does not create anaccident of a different type. Therefore, the revised analysis for the Control Rod EjectionAccident could be implemented without prior NRC review and approval.13-003 Regulatory Evaluation 10/01/13Description:

Regulatory Evaluation 13-003 reviewed several areas affected by revisedLOCA and seismic loads reflecting the assumption of an updated reactor vessel lowerradial key stiffness value. The issue and its effects are discussed in Westinghouse letterNSAL-1 1-2, Impact of Change in Lower Radial Key Stiffness Value, dated June 28, 2011.Summary:

Changes to the Reload Transition Safety Report for the 15 x 15 Upgrade Fueldesign involve revising the analysis to reflect assumption of an updated reactor vessellower radial key stiffness value. The revised analysis in the report evaluated increased stresses to the reactor vessel structure, reactor cooling line piping, reactor coolant pumpsupport, control rod drive mechanism, and Unit 1 & 2 reactor vessel closure heads.The regulatory evaluation determined the areas reviewed do not impact the associated design function, exceed or alter a design basis limits for fission product barriers, or result ina departure in a method of evaluation as described in the UFSAR. Therefore, the revisedanalysis could be implemented without prior NRC review and approval.

Serial No. 14-11310 CFR 50.59 ReportPage 4 of 4Attachment 1Surry Units 1 & 22013 -10 CFR 50.59 Changes, Tests and Experiments Commitment Evaluation Summary 11/22/13Description:

This Commitment Evaluation documented modifications andmethodologies of operation for Surry's Containment Spray (CS) and OutsideRecirculation Spray (RS) containment isolation check valves.Summary:

LER 88-012 documented an outside RS containment isolation check valvefound in the open position when it was required to be closed. Actions to preventrecurrence modified the eight Surry Unit 1 & 2 CS and RS check valves by reducing thecounterweight arm angle to zero degrees from the horizontal position with the valveclosed. This adjustment was made to prevent the valve from being capable of remaining in the open position.

The LER commitment,

however, did not consider the affect of the adjustment under designflow conditions and the potential for reduced margins in system delivered flow. When theLER commitment was made, analytical methods to determine the capability of the checkvalves to fully open did not exist. The current position for the check valves was calculated using EPRI Report NP 5479, Application Guide for Check Valves in Nuclear Power Plants.The ability of the components to meet design requirements is assured via flow calculations along with validation of the valve's ability to open freely and close without assistance.

Therefore, the need for a commitment to ensure the valves remain capable of meetingdesign requirements is unnecessary.