ML18153A345: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
Line 21: Line 21:
=Text=
=Text=
{{#Wiki_filter:*
{{#Wiki_filter:*
VIRGINIA ELECTRIC AND PowER CoMPANY RICHMOND, VIRGINIA 23261 e                          1 December 18, 1997 U.S. Nuclear Regulatory Commission                                             Serial No. 97-653 Attention: Document Control Desk                                               NL&OS/GDM RO Washington, D.C. 20555                                                         Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen:
e VIRGINIA ELECTRIC AND PowER CoMPANY RICHMOND, VIRGINIA 23261 December 18, 1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE CLARIFICATION OF REFUELING INTERVAL SURVEILLANCE FREQUENCY Pursuant to 10 CFR 50.90, Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications, to Facility Operating License Numbers DPR-32 and 37 for Surry Power Station Units 1 and 2.
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE Serial No.
The proposed change will revise the Technical Specifications to clarify the terminology used for describing equipment surveillances conducted on a refueling interval frequency. The proposed clarification to the. refueling interval surveillances is consistent with the specified frequency provided in Revision 1 of NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," dated April 1995.
97-653 NL&OS/GDM RO Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 CLARIFICATION OF REFUELING INTERVAL SURVEILLANCE FREQUENCY Pursuant to 10 CFR 50.90, Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications, to Facility Operating License Numbers DPR-32 and 37 for Surry Power Station Units 1 and 2.
A discussion of the proposed Technical Specifications change is provided in .       The proposed Technical Specifications pages are provided in . It has been determined that the proposed Technical Specifications change does not involve an unreviewed safety question as defined in 10 CFR 50.59 or a significant hazards consideration as defined in 10 CFR 50.92. The basis for our determination that the changes do not involve a significant hazards consideration is provided in Attachment 3. The proposed Technical Specifications change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Management Safety Review Committee.
The proposed change will revise the Technical Specifications to clarify the terminology used for describing equipment surveillances conducted on a refueling interval frequency.
The proposed clarification to the. refueling interval surveillances is consistent with the specified frequency provided in Revision 1 of NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," dated April 1995.
A discussion of the proposed Technical Specifications change is provided in.
The proposed Technical Specifications pages are provided in.
It has been determined that the proposed Technical Specifications change does not involve an unreviewed safety question as defined in 10 CFR 50.59 or a significant hazards consideration as defined in 10 CFR 50.92. The basis for our determination that the changes do not involve a significant hazards consideration is provided in Attachment 3. The proposed Technical Specifications change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Management Safety Review Committee.
Should you have any questions or require additional information, please contact us.
Should you have any questions or require additional information, please contact us.
                    -----~---
Very truly yours, ;
Very truly yours, ;      9801020023 -9*f12i8-- -
-----~---
                        ~DR     ADOCK 05000280 PDR                                     {Ai]DI
9801020023 -9*f12i8--
            . Ye,?/~
~DR ADOCK 05000280 PDR  
~
. Ye,?/~  
James P. O'Hanlon
~  
                                              ...   *.,o**---
... *.,o**---
01 :,j v LJ       I Senior Vice President - Nuclear 11111111111111111
James P. O'Hanlon 01 :,j v I LJ Senior Vice President - Nuclear 11111111111111111 IIIIII IIIII IIIII 1111111 *
                                  *&&2FCA*.
*&&2FCA*.
IIIIII IIIII IIIII 1111111
{Ai]DI 1
* Attachments
: 1. Discussion of Change
: 2. Proposed Technical Specifications Change
: 3. Significant Hazards Consideration Determination cc:  U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRG Senior Resident Inspector Surry Power Station Commissioner Bureau of Radiological Health Room 104A 1500 East Main Street Richmond, Virginia 23219 Commitment Summary
: 1. The commitments made in this letter are as indicated in the proposed Technical Specifications.


e COMMONWEALTH OF VIRGINIA                )
Attachments 1.
                                        )
Discussion of Change
COUNTY OF HENRICO                      )
: 2.
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. P. O'Hanlon, who is Senior Vice President - Nuclear, of 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 that Company, and that the statements in the document are true to the best of his knowledge and belief.
Proposed Technical Specifications Change
Acknowledged before me this /  8w day of ~cemtJlr          , 19 CJ1 .
: 3.
My Commission Expires: March 31, 2000 .
Significant Hazards Consideration Determination cc:
  ./ .
U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRG Senior Resident Inspector Surry Power Station Commissioner Bureau of Radiological Health Room 104A 1500 East Main Street Richmond, Virginia 23219 Commitment Summary
: 1.
The commitments made in this letter are as indicated in the proposed Technical Specifications.  


Attachment 1 Discussion of Change
e COMMONWEAL TH OF VIRGINIA
)
)
COUNTY OF HENRICO
)
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. P. O'Hanlon, who is Senior Vice President - Nuclear, of 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 that Company, and that the statements in the document are true to the best of his knowledge and belief.
. /.
Acknowledged before me this / 8w day of ~cemtJlr
, 19 CJ1.
My Commission Expires: March 31, 2000.
Discussion of Change  


e                                     e DISCUSSION OF CHANGE INTRODUCTION The equipment surveillance requirements contained in Section 4 of the Surry Technical Specifications currently include inconsistent terminology when specifying surveillance testing to be performed on a refueling interval frequency. The inconsistent terminology is confusing and lends itself to potential misinterpretation with regard to verbatim compliance. Therefore, the refueling interval surveillance frequencies specified in Section 4 will be clarified to ensure system/component surveillances are consistently specified and are performed at the appropriate frequency. The proposed clarification to the refueling interval surveillances is consistent with the specified frequency provided in Revision 1 of NUREG-1431, "Standard Technical Specifications, Westinghouse Plants,"
e e
DISCUSSION OF CHANGE INTRODUCTION The equipment surveillance requirements contained in Section 4 of the Surry Technical Specifications currently include inconsistent terminology when specifying surveillance testing to be performed on a refueling interval frequency. The inconsistent terminology is confusing and lends itself to potential misinterpretation with regard to verbatim compliance.
Therefore, the refueling interval surveillance frequencies specified in Section 4 will be clarified to ensure system/component surveillances are consistently specified and are performed at the appropriate frequency. The proposed clarification to the refueling interval surveillances is consistent with the specified frequency provided in Revision 1 of NUREG-1431, "Standard Technical Specifications, Westinghouse Plants,"
dated April 1995. In addition, minor typographical errors are also being corrected and an obsolete reference is being deleted.
dated April 1995. In addition, minor typographical errors are also being corrected and an obsolete reference is being deleted.
The probability of an accident or equipment malfunction is not increased since surveillance intervals are being clarified, not changed, and will continue to validate system availability, operability and performance. The consequences of an accident previously evaluated are not increased since the station is not being operated differently, and no physical modifications are being made to plant systems or components. A new or different type of accident is not being created since the surveillances will continue to be performed as required to ensure plant systems/components will perform their intended plant function. The margin of safety is not reduced since the surveillances will continue to ensure system performance as assumed in the existing design basis accident safety analyses.
The probability of an accident or equipment malfunction is not increased since surveillance intervals are being clarified, not changed, and will continue to validate system availability, operability and performance. The consequences of an accident previously evaluated are not increased since the station is not being operated differently, and no physical modifications are being made to plant systems or components.
A new or different type of accident is not being created since the surveillances will continue to be performed as required to ensure plant systems/components will perform their intended plant function. The margin of safety is not reduced since the surveillances will continue to ensure system performance as assumed in the existing design basis accident safety analyses.
BACKGROUND The Technical Specifications establish surveillance requirements for systems and components directly related to safety limits and limiting conditions for operation. These requirements ensure that the systems/components will perform their intended plant function consistent with safe plant operation and as assumed by the safety analyses.
BACKGROUND The Technical Specifications establish surveillance requirements for systems and components directly related to safety limits and limiting conditions for operation. These requirements ensure that the systems/components will perform their intended plant function consistent with safe plant operation and as assumed by the safety analyses.
Section 4 of the Technical Specifications specifies the type of surveillance to be performed for systems/components and the minimum performance frequency. The surveillance intervals range from hours, days, months, and quarters to refueling frequencies.
Section 4 of the Technical Specifications specifies the type of surveillance to be performed for systems/components and the minimum performance frequency.
The Surry Units 1 and 2 Technical Specifications were issued in 1972 and 1973, respectively, and are customized specifications* since they pre-date the Standard Technical Specifications format.         The original issue of the Surry Technical Specifications included various terms to refer to refueling interval surveillances. The terms "each refueling," "each refueling shutdown," "once per refueling cycle," "refueling interval" and similar variations have all been used in the Surry Technical Specifications to designate refueling interval surveillance frequencies. However, the basis for the 1 of 7
The surveillance intervals range from hours, days, months, and quarters to refueling frequencies.
The Surry Units 1 and 2 Technical Specifications were issued in 1972 and 1973, respectively, and are customized specifications* since they pre-date the Standard Technical Specifications format.
The original issue of the Surry Technical Specifications included various terms to refer to refueling interval surveillances. The terms "each refueling," "each refueling shutdown," "once per refueling cycle," "refueling interval" and similar variations have all been used in the Surry Technical Specifications to designate refueling interval surveillance frequencies.
However, the basis for the 1 of 7  


l BACKGROUND (continued) e
e BACKGROUND (continued) different terms is neither evident nor clearly documented in the Technical Specifications or supporting documents.
* different terms is neither evident nor clearly documented in the Technical Specifications or supporting documents. Furthermore, as the Technical Specifications have been amended over the past twenty-five years, these. differing terms have been used             1 interchangeably. The use of these different terms for refueling interval surveillances has caused confusion when interpreting the surveillance requirements because it is not clear if the surveillances were intended to be performed when a unit is shutdown for refueling, during the defined REFUELING SHUTDOWN mode, or at a refueling interval frequency. Therefore, the surveillance requirements specified in Section 4 of the Technical Specifications that reference the term "refueling" in any form have been reviewed. In each instance, the proposed change replaces the existing inconsistent refueling interval terminology with a specified frequency of "once per 18 months,"
Furthermore, as the Technical Specifications have been amended over the past twenty-five years, these. differing terms have been used 1
interchangeably. The use of these different terms for refueling interval surveillances has caused confusion when interpreting the surveillance requirements because it is not clear if the surveillances were intended to be performed when a unit is shutdown for refueling, during the defined REFUELING SHUTDOWN mode, or at a refueling interval frequency.
Therefore, the surveillance requirements specified in Section 4 of the Technical Specifications that reference the term "refueling" in any form have been reviewed. In each instance, the proposed change replaces the existing inconsistent refueling interval terminology with a specified frequency of "once per 18 months,"
consistent with NUREG-1431. Any unit mode restrictions required for the performance of each surveillance test is properly addressed and controlled by the applicable surveillance test procedures.
consistent with NUREG-1431. Any unit mode restrictions required for the performance of each surveillance test is properly addressed and controlled by the applicable surveillance test procedures.
The existing refueling interval surveillances equate to a nominal 18 month refueling cycle. Technical Specification 4.0.2 permits this interval to be adjusted plus or minus 25 percent which allows refueling interval surveillances to be performed up to 22.5 months following the previous performance of the surveillance. This adjustment also allows such surveillances to be performed on a more frequent basis, including the period before a refueling outage. The clarification of refueling surveillance interval terminology does not increase the existing refueling interval nor the allowable adjustment. Refueling interval surveillances will continue to be performed on a nominal 18 month or more frequent basis and will not, in any case, exceed 22.5 months following the previous performance of the surveillance. Therefore, surveillance intervals are not being increased by the proposed Technical Specifications change.
The existing refueling interval surveillances equate to a nominal 18 month refueling cycle. Technical Specification 4.0.2 permits this interval to be adjusted plus or minus 25 percent which allows refueling interval surveillances to be performed up to 22.5 months following the previous performance of the surveillance. This adjustment also allows such surveillances to be performed on a more frequent basis, including the period before a refueling outage.
In addition, minor typographical errors are also being corrected, and an obsolete reference is being deleted. A reference to the station operating records retention requirements previously contained in Specification 6.5 is still included in Specification 4.17, Shock Suppressors (Snubbers). However, Specification 6.5 was deleted by Amendments 211, and the records retention requirements were relocated to the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report (QA Topical Report). Specification 4.17 will be corrected to reflect the QA Topical Report rather than the deleted Specification 6.5.
The clarification of refueling surveillance interval terminology does not increase the existing refueling interval nor the allowable adjustment. Refueling interval surveillances will continue to be performed on a nominal 18 month or more frequent basis and will not, in any case, exceed 22.5 months following the previous performance of the surveillance. Therefore, surveillance intervals are not being increased by the proposed Technical Specifications change.
In addition, minor typographical errors are also being corrected, and an obsolete reference is being deleted.
A reference to the station operating records retention requirements previously contained in Specification 6.5 is still included in Specification 4.17, Shock Suppressors (Snubbers).
However, Specification 6.5 was deleted by Amendments 211, and the records retention requirements were relocated to the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report (QA Topical Report).
Specification 4.17 will be corrected to reflect the QA Topical Report rather than the deleted Specification 6.5.
SPECIFIC CHANGES Section 4 of the Surry Technical Specifications, and the associated Bases as required, are being revised to clarify the intent of the refueling interval surveillances and to use consistent wording.
SPECIFIC CHANGES Section 4 of the Surry Technical Specifications, and the associated Bases as required, are being revised to clarify the intent of the refueling interval surveillances and to use consistent wording.
2 of 7
2 of 7 l


Specific changes to the Technical Specifications (TS) and Bases are being made as follows:
Specific changes to the Technical Specifications (TS) and Bases are being made as follows:
* TS 4.1.B.1.a and b The TS surveillance frequency associated with the Pressurizer Power Operated Relief Valves is revised to read "once per 18 months" rather than "at least once per refueling cycle."
TS 4.1.B.1.a and b The TS surveillance frequency associated with the Pressurizer Power Operated Relief Valves is revised to read "once per 18 months" rather than "at least once per refueling cycle."
* TS Basis 4.1 The discussion of the minimum calibration frequency for the process system channels in the Basis section is also revised to read "once per 18 months" rather than "each refueling shutdown." A typographical error is also corrected in the same sentence. The verb "is" is changed to "are" to agree with the plural subject "frequencies."
TS Basis 4.1 The discussion of the minimum calibration frequency for the process system channels in the Basis section is also revised to read "once per 18 months" rather than "each refueling shutdown." A typographical error is also corrected in the same sentence. The verb "is" is changed to "are" to agree with the plural subject "frequencies."
The discussion of the control room pressurization test frequency in the last paragraph of the Basis section is revised from "each refueling interval (approximately 12 to 18 months)" to "once per 18 months."
The discussion of the control room pressurization test frequency in the last paragraph of the Basis section is revised from "each refueling interval (approximately 12 to 18 months)" to "once per 18 months."
* Table 4.1-1 The legend at the end of Table 4.1-1, Minimum Frequencies for Check, Calibrations and Test of Instrument Channels, that provides the definitions for the surveillance frequency abbreviations used in the Table is revised as follows:
Table 4.1-1 The legend at the end of Table 4.1-1, Minimum Frequencies for Check, Calibrations and Test of Instrument Channels, that provides the definitions for the surveillance frequency abbreviations used in the Table is revised as follows:
From "R - Each Refueling Shutdown" to "R - Once per 18 months."
From "R - Each Refueling Shutdown" to "R - Once per 18 months."
* Table 4.1-2 The legend at the end of Table 4.1-2, Accident Monitoring Instrumentation Surveillance Requirements, that provides the definitions for the surveillance frequency abbreviations used in the Table is revised as follows:
Table 4.1-2 The legend at the end of Table 4.1-2, Accident Monitoring Instrumentation Surveillance Requirements, that provides the definitions for the surveillance frequency abbreviations used in the Table is revised as follows:
From "R - Refueling" to "R - Once per 18 months."
From "R - Refueling" to "R - Once per 18 months."
* Table 4.1-2A The surveillance interval frequencies specified in Table 4.1-2A, Minimum Frequency For Equipment Tests, items 1.c, 3, 6, 8, 14.a and b, 15, 16, 17, 18, and 22 are revised as follows:
Table 4.1-2A The surveillance interval frequencies specified in Table 4.1-2A, Minimum Frequency For Equipment Tests, items 1.c, 3, 6, 8, 14.a and b, 15, 16, 17, 18, and 22 are revised as follows:
From "Each refueling shutdown," "Each Refueling Shutdown" or "Once per refueling cycle" to "Once per 18 months."
From "Each refueling shutdown," "Each Refueling Shutdown" or "Once per refueling cycle" to "Once per 18 months."
3 of 7
3 of 7  


e SPECIFIC CHANGES (continued)
e SPECIFIC CHANGES (continued)
* Table 4.2-1 The augmented inspection schedules noted in the Remarks section for Table items 1.2, 2.1 .1, and 2.1 .2 are revised to note that the subject inspections will be performed "once per 18 months" rather than "each refueling outage" or "each refueling shutdown" as currently stated.
Table 4.2-1 The augmented inspection schedules noted in the Remarks section for Table items 1.2, 2.1.1, and 2.1.2 are revised to note that the subject inspections will be performed "once per 18 months" rather than "each refueling outage" or "each refueling shutdown" as currently stated.
* TS 4.5. C and D The surveillance frequency for demonstrating the operability of the containment spray and outside recirculation spray weight-loaded check valves, and for visually inspecting the containment sump, inside containment recirculation spray pump wells and the engineered safeguards suction inlets is revised from "at least once each refueling period" to "once per 18 months."
TS 4.5. C and D The surveillance frequency for demonstrating the operability of the containment spray and outside recirculation spray weight-loaded check valves, and for visually inspecting the containment sump, inside containment recirculation spray pump wells and the engineered safeguards suction inlets is revised from "at least once each refueling period" to "once per 18 months."
* TS 4.5 Basis The Basis section for the spray systems is revised to 1) state that the flow test for the inside recirculation spray pumps is impractical to perform other than "during a unit outage" rather than "on a refueling outage frequency", and 2) that the flow-test will be performed "once per 18 months during a unit outage," as opposed to "on a refueling outage frequency" as currently stated.
TS 4.5 Basis The Basis section for the spray systems is revised to 1) state that the flow test for the inside recirculation spray pumps is impractical to perform other than "during a unit outage" rather than "on a refueling outage frequency", and 2) that the flow-test will be performed "once per 18 months during a unit outage," as opposed to "on a refueling outage frequency" as currently stated.  
\(
\\(
* TS 4.6.A.1.b and d: C.1.e and f: D.1.d and e The surveillance frequencies for the emergency diesel auto-start test and inspection, and the station and emergency diesel generator batteries' load tests and connection checks are revised from the various references to refueling interval surveillances to "once per 18 months."
TS 4.6.A.1.b and d: C.1.e and f: D.1.d and e The surveillance frequencies for the emergency diesel auto-start test and inspection, and the station and emergency diesel generator batteries' load tests and connection checks are revised from the various references to refueling interval surveillances to "once per 18 months."
* TS 4.11.C.5 The refueling interval surveillance frequency associated with safety injection subsystem testing is revised from "once per REFUELING SHUTDOWN" to "Once per 18 months." This testing is not required to be performed in the REFUELING SHUTDOWN mode.
TS 4.11.C.5 The refueling interval surveillance frequency associated with safety injection subsystem testing is revised from "once per REFUELING SHUTDOWN" to "Once per 18 months." This testing is not required to be performed in the REFUELING SHUTDOWN mode.
* TS 4.11 Basis The term "refueling shutdowns" used to note the time period for the performance of certain safety injection system tests is revised to read "unit outages" instead to avoid confusion with an actual specific unit mode requirement that was not intended.
TS 4.11 Basis The term "refueling shutdowns" used to note the time period for the performance of certain safety injection system tests is revised to read "unit outages" instead to avoid confusion with an actual specific unit mode requirement that was not intended.
4 of 7
4 of 7  


SPECIFIC CHANGES (continued}
SPECIFIC CHANGES (continued}
* TS 4.12.A.2, 3, 6b, 7b, 8b, and 9b The surveillance frequencies specified for various auxiliary ventilation exhaust filter train tests are "At least once per refueling cycle" or "At least once per refueling cycle, i.e., approximately 18 months" or a slight variation thereof. The surveillance frequencies for these various tests are revised to "once per 18 months."
TS 4.12.A.2, 3, 6b, 7b, 8b, and 9b The surveillance frequencies specified for various auxiliary ventilation exhaust filter train tests are "At least once per refueling cycle" or "At least once per refueling cycle, i.e., approximately 18 months" or a slight variation thereof. The surveillance frequencies for these various tests are revised to "once per 18 months."
* TS 4.12.A.5 A typographical error is corrected. The last sentence of this specification ends with the words, "... and at the center of each carbon filters." The word "filters" is revised to "filter" for agreement with the singular modifier "each."
TS 4.12.A.5 A typographical error is corrected. The last sentence of this specification ends with the words, "... and at the center of each carbon filters." The word "filters" is revised to "filter" for agreement with the singular modifier "each."
* TS 4.17.C.1 The surveillance frequency specified for snubber functional testing is "At least once per 18 months during shutdown." The surveillance frequency for this testing is revised to "Once per 18 months."
TS 4.17.C.1 The surveillance frequency specified for snubber functional testing is "At least once per 18 months during shutdown."
* TS 4.17.F.1 This specification is revised to correct the statement that the records of service life of each snubber are maintained as required by Specification 6.5.B.9.
The surveillance frequency for this testing is revised to "Once per 18 months."
TS 4.17.F.1 This specification is revised to correct the statement that the records of service life of each snubber are maintained as required by Specification 6.5.B.9.
Specification 6.5 addressed Station Operating Records retention requirements but was recently deleted from the Technical Specifications by Amendments 211.
Specification 6.5 addressed Station Operating Records retention requirements but was recently deleted from the Technical Specifications by Amendments 211.
Record retention requirements are now contained in the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report (QA Topical Report). The reference to Specification 6.5 in Specification 4.17.F.1 was inadvertently left unchanged during preparation of the previous Technical Specification change request to relocate the station operating records retention requirements to the bA Topical Report. Specification 4.17.F.1 will now reference the QA Topical Report for snubber service life records maintenance.
Record retention requirements are now contained in the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report (QA Topical Report). The reference to Specification 6.5 in Specification 4.17.F.1 was inadvertently left unchanged during preparation of the previous Technical Specification change request to relocate the station operating records retention requirements to the bA Topical Report. Specification 4.17.F.1 will now reference the QA Topical Report for snubber service life records maintenance.
* TS Bases 4.17 The discussion regarding snubber functional testing is revised to read "once per 18 months" rather than "during plant shutdowns at 18 month intervals."
TS Bases 4.17 The discussion regarding snubber functional testing is revised to read "once per 18 months" rather than "during plant shutdowns at 18 month intervals."
5 of 7
5 of 7  


e SPECIFIC CHANGES (continued)
e SPECIFIC CHANGES (continued)
* TS 4.20.A.1.b, 3.b, 5.b, 7.b, and 9.b The surveillance frequency specified for various control room air filtration system tests is "At least once per refueling cycle, i.e., approximately every eighteen months." The surveillance frequency for these various tests is revised to "Once per 18 months."
TS 4.20.A.1.b, 3.b, 5.b, 7.b, and 9.b The surveillance frequency specified for various control room air filtration system tests is "At least once per refueling cycle, i.e., approximately every eighteen months." The surveillance frequency for these various tests is revised to "Once per 18 months."
The refueling interval surveillance requirements in Technical Specification 4.18, Fire Detection and Protection System Surveillance, are not being revised in this proposed change request. A Technical Specifications change request has been previously submitted to the NRC that relocates TS 4.18 surveillance requirements from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR). Any required changes to this section will be appropriately addressed in a subsequent revision to the UFSAR.
The refueling interval surveillance requirements in Technical Specification 4.18, Fire Detection and Protection System Surveillance, are not being revised in this proposed change request.
SAFETY SIGNIFICANCE The proposed change updates the Technical Specifications to clarify the refueling interval surveillance frequencies provided in Section 4, Surveillance Requirements. The change does not increase the existing refueling interval nor the allowable adjustment and is consistent with NUREG-1431 Revision 1.             Since the time interval to perform surveillances is not being increased, there is no effect on the equipment being tested (e.g., instrument drift) as a result of the proposed Technical Specifications change.
A Technical Specifications change request has been previously submitted to the NRC that relocates TS 4.18 surveillance requirements from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR). Any required changes to this section will be appropriately addressed in a subsequent revision to the UFSAR.
SAFETY SIGNIFICANCE The proposed change updates the Technical Specifications to clarify the refueling interval surveillance frequencies provided in Section 4, Surveillance Requirements. The change does not increase the existing refueling interval nor the allowable adjustment and is consistent with NUREG-1431 Revision 1.
Since the time interval to perform surveillances is not being increased, there is no effect on the equipment being tested (e.g., instrument drift) as a result of the proposed Technical Specifications change.
Therefore, the proposed change is administrative in nature and has no effect on system/component operability.
Therefore, the proposed change is administrative in nature and has no effect on system/component operability.
The surveillance tests will continue to be performed in the required unit mode to ensure plant safety is not compromised. The initial conditions and any unit restrictions required for the performance of each surveillance test are properly addressed and controlled by the applicable surveillance test procedures. Furthermore, the removal of risk significant equipment from service for surveillance testing is appropriately reviewed against the on-line maintenance risk matrix to assure that risk is minimized. Also, surveillances must be performed within the allowed* outage times specified for the affected system/components in the applicable Technical Specifications which have been previously considered and determined to be acceptable.
The surveillance tests will continue to be performed in the required unit mode to ensure plant safety is not compromised. The initial conditions and any unit restrictions required for the performance of each surveillance test are properly addressed and controlled by the applicable surveillance test procedures. Furthermore, the removal of risk significant equipment from service for surveillance testing is appropriately reviewed against the on-line maintenance risk matrix to assure that risk is minimized. Also, surveillances must be performed within the allowed* outage times specified for the affected system/components in the applicable Technical Specifications which have been previously considered and determined to be acceptable.
The probability of an accident or equipment malfunction is not increased as a result of this Technical Specifications change request since surveillance intervals are being clarified, not changed, and will continue to validate system/component availability and performance. The consequences of an accident previously evaluated are not increased since station operations are not being changed, and no physical modifications are being made to plant systems or components. A new or different type of accident is not being 6 of 7
The probability of an accident or equipment malfunction is not increased as a result of this Technical Specifications change request since surveillance intervals are being clarified, not changed, and will continue to validate system/component availability and performance. The consequences of an accident previously evaluated are not increased since station operations are not being changed, and no physical modifications are being made to plant systems or components. A new or different type of accident is not being 6 of 7  
                                                                                            ~I
~I


SAFETY SIGNIFICANCE (continued) created since the surveillances will continue to be performed in the applicable unit mode as required to ensure proper system/component operations. The margin of safety is not reduced since the surveillances will continue to ensure system/component performance as assumed in the existing safety analyses. Therefore, this administrative change to Technical Specifications has no impact on safety and does not result in an unreviewed safety question.
SAFETY SIGNIFICANCE (continued) created since the surveillances will continue to be performed in the applicable unit mode as required to ensure proper system/component operations.
The margin of safety is not reduced since the surveillances will continue to ensure system/component performance as assumed in the existing safety analyses. Therefore, this administrative change to Technical Specifications has no impact on safety and does not result in an unreviewed safety question.
7 of 7}}
7 of 7}}

Latest revision as of 19:30, 5 January 2025

Application for Amends to Licenses DPR-32 & DPR-37, Clarifying Terminology Used for Describing Equipment Surveillances Conducted in Refueling Interval Frequency. Amend Consistent W/Info Provided in Rev 1 of NUREG-1431
ML18153A345
Person / Time
Site: Surry  Dominion icon.png
Issue date: 12/18/1997
From: Ohanlon J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18153A346 List:
References
RTR-NUREG-1431 97-653, NUDOCS 9801020023
Download: ML18153A345 (11)
v • d • e


Text

e VIRGINIA ELECTRIC AND PowER CoMPANY RICHMOND, VIRGINIA 23261 December 18, 1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE Serial No.97-653 NL&OS/GDM RO Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 CLARIFICATION OF REFUELING INTERVAL SURVEILLANCE FREQUENCY Pursuant to 10 CFR 50.90, Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications, to Facility Operating License Numbers DPR-32 and 37 for Surry Power Station Units 1 and 2.

The proposed change will revise the Technical Specifications to clarify the terminology used for describing equipment surveillances conducted on a refueling interval frequency.

The proposed clarification to the. refueling interval surveillances is consistent with the specified frequency provided in Revision 1 of NUREG-1431, "Standard Technical Specifications, Westinghouse Plants," dated April 1995.

A discussion of the proposed Technical Specifications change is provided in.

The proposed Technical Specifications pages are provided in.

It has been determined that the proposed Technical Specifications change does not involve an unreviewed safety question as defined in 10 CFR 50.59 or a significant hazards consideration as defined in 10 CFR 50.92. The basis for our determination that the changes do not involve a significant hazards consideration is provided in Attachment 3. The proposed Technical Specifications change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Management Safety Review Committee.

Should you have any questions or require additional information, please contact us.

Very truly yours, ;

~---

9801020023 -9*f12i8--

~DR ADOCK 05000280 PDR

. Ye,?/~

~

... *.,o**---

James P. O'Hanlon 01 :,j v I LJ Senior Vice President - Nuclear 11111111111111111 IIIIII IIIII IIIII 1111111 *

  • &&2FCA*.

{Ai]DI 1

Attachments 1.

Discussion of Change

2.

Proposed Technical Specifications Change

3.

Significant Hazards Consideration Determination cc:

U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRG Senior Resident Inspector Surry Power Station Commissioner Bureau of Radiological Health Room 104A 1500 East Main Street Richmond, Virginia 23219 Commitment Summary

1.

The commitments made in this letter are as indicated in the proposed Technical Specifications.

e COMMONWEAL TH OF VIRGINIA

)

)

COUNTY OF HENRICO

)

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. P. O'Hanlon, who is Senior Vice President - Nuclear, of 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 that Company, and that the statements in the document are true to the best of his knowledge and belief.

. /.

Acknowledged before me this / 8w day of ~cemtJlr

, 19 CJ1.

My Commission Expires: March 31, 2000.

Discussion of Change

e e

DISCUSSION OF CHANGE INTRODUCTION The equipment surveillance requirements contained in Section 4 of the Surry Technical Specifications currently include inconsistent terminology when specifying surveillance testing to be performed on a refueling interval frequency. The inconsistent terminology is confusing and lends itself to potential misinterpretation with regard to verbatim compliance.

Therefore, the refueling interval surveillance frequencies specified in Section 4 will be clarified to ensure system/component surveillances are consistently specified and are performed at the appropriate frequency. The proposed clarification to the refueling interval surveillances is consistent with the specified frequency provided in Revision 1 of NUREG-1431, "Standard Technical Specifications, Westinghouse Plants,"

dated April 1995. In addition, minor typographical errors are also being corrected and an obsolete reference is being deleted.

The probability of an accident or equipment malfunction is not increased since surveillance intervals are being clarified, not changed, and will continue to validate system availability, operability and performance. The consequences of an accident previously evaluated are not increased since the station is not being operated differently, and no physical modifications are being made to plant systems or components.

A new or different type of accident is not being created since the surveillances will continue to be performed as required to ensure plant systems/components will perform their intended plant function. The margin of safety is not reduced since the surveillances will continue to ensure system performance as assumed in the existing design basis accident safety analyses.

BACKGROUND The Technical Specifications establish surveillance requirements for systems and components directly related to safety limits and limiting conditions for operation. These requirements ensure that the systems/components will perform their intended plant function consistent with safe plant operation and as assumed by the safety analyses.

Section 4 of the Technical Specifications specifies the type of surveillance to be performed for systems/components and the minimum performance frequency.

The surveillance intervals range from hours, days, months, and quarters to refueling frequencies.

The Surry Units 1 and 2 Technical Specifications were issued in 1972 and 1973, respectively, and are customized specifications* since they pre-date the Standard Technical Specifications format.

The original issue of the Surry Technical Specifications included various terms to refer to refueling interval surveillances. The terms "each refueling," "each refueling shutdown," "once per refueling cycle," "refueling interval" and similar variations have all been used in the Surry Technical Specifications to designate refueling interval surveillance frequencies.

However, the basis for the 1 of 7

e BACKGROUND (continued) different terms is neither evident nor clearly documented in the Technical Specifications or supporting documents.

Furthermore, as the Technical Specifications have been amended over the past twenty-five years, these. differing terms have been used 1

interchangeably. The use of these different terms for refueling interval surveillances has caused confusion when interpreting the surveillance requirements because it is not clear if the surveillances were intended to be performed when a unit is shutdown for refueling, during the defined REFUELING SHUTDOWN mode, or at a refueling interval frequency.

Therefore, the surveillance requirements specified in Section 4 of the Technical Specifications that reference the term "refueling" in any form have been reviewed. In each instance, the proposed change replaces the existing inconsistent refueling interval terminology with a specified frequency of "once per 18 months,"

consistent with NUREG-1431. Any unit mode restrictions required for the performance of each surveillance test is properly addressed and controlled by the applicable surveillance test procedures.

The existing refueling interval surveillances equate to a nominal 18 month refueling cycle. Technical Specification 4.0.2 permits this interval to be adjusted plus or minus 25 percent which allows refueling interval surveillances to be performed up to 22.5 months following the previous performance of the surveillance. This adjustment also allows such surveillances to be performed on a more frequent basis, including the period before a refueling outage.

The clarification of refueling surveillance interval terminology does not increase the existing refueling interval nor the allowable adjustment. Refueling interval surveillances will continue to be performed on a nominal 18 month or more frequent basis and will not, in any case, exceed 22.5 months following the previous performance of the surveillance. Therefore, surveillance intervals are not being increased by the proposed Technical Specifications change.

In addition, minor typographical errors are also being corrected, and an obsolete reference is being deleted.

A reference to the station operating records retention requirements previously contained in Specification 6.5 is still included in Specification 4.17, Shock Suppressors (Snubbers).

However, Specification 6.5 was deleted by Amendments 211, and the records retention requirements were relocated to the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report (QA Topical Report).

Specification 4.17 will be corrected to reflect the QA Topical Report rather than the deleted Specification 6.5.

SPECIFIC CHANGES Section 4 of the Surry Technical Specifications, and the associated Bases as required, are being revised to clarify the intent of the refueling interval surveillances and to use consistent wording.

2 of 7 l

Specific changes to the Technical Specifications (TS) and Bases are being made as follows:

TS 4.1.B.1.a and b The TS surveillance frequency associated with the Pressurizer Power Operated Relief Valves is revised to read "once per 18 months" rather than "at least once per refueling cycle."

TS Basis 4.1 The discussion of the minimum calibration frequency for the process system channels in the Basis section is also revised to read "once per 18 months" rather than "each refueling shutdown." A typographical error is also corrected in the same sentence. The verb "is" is changed to "are" to agree with the plural subject "frequencies."

The discussion of the control room pressurization test frequency in the last paragraph of the Basis section is revised from "each refueling interval (approximately 12 to 18 months)" to "once per 18 months."

Table 4.1-1 The legend at the end of Table 4.1-1, Minimum Frequencies for Check, Calibrations and Test of Instrument Channels, that provides the definitions for the surveillance frequency abbreviations used in the Table is revised as follows:

From "R - Each Refueling Shutdown" to "R - Once per 18 months."

Table 4.1-2 The legend at the end of Table 4.1-2, Accident Monitoring Instrumentation Surveillance Requirements, that provides the definitions for the surveillance frequency abbreviations used in the Table is revised as follows:

From "R - Refueling" to "R - Once per 18 months."

Table 4.1-2A The surveillance interval frequencies specified in Table 4.1-2A, Minimum Frequency For Equipment Tests, items 1.c, 3, 6, 8, 14.a and b, 15, 16, 17, 18, and 22 are revised as follows:

From "Each refueling shutdown," "Each Refueling Shutdown" or "Once per refueling cycle" to "Once per 18 months."

3 of 7

e SPECIFIC CHANGES (continued)

Table 4.2-1 The augmented inspection schedules noted in the Remarks section for Table items 1.2, 2.1.1, and 2.1.2 are revised to note that the subject inspections will be performed "once per 18 months" rather than "each refueling outage" or "each refueling shutdown" as currently stated.

TS 4.5. C and D The surveillance frequency for demonstrating the operability of the containment spray and outside recirculation spray weight-loaded check valves, and for visually inspecting the containment sump, inside containment recirculation spray pump wells and the engineered safeguards suction inlets is revised from "at least once each refueling period" to "once per 18 months."

TS 4.5 Basis The Basis section for the spray systems is revised to 1) state that the flow test for the inside recirculation spray pumps is impractical to perform other than "during a unit outage" rather than "on a refueling outage frequency", and 2) that the flow-test will be performed "once per 18 months during a unit outage," as opposed to "on a refueling outage frequency" as currently stated.

\\(

TS 4.6.A.1.b and d: C.1.e and f: D.1.d and e The surveillance frequencies for the emergency diesel auto-start test and inspection, and the station and emergency diesel generator batteries' load tests and connection checks are revised from the various references to refueling interval surveillances to "once per 18 months."

TS 4.11.C.5 The refueling interval surveillance frequency associated with safety injection subsystem testing is revised from "once per REFUELING SHUTDOWN" to "Once per 18 months." This testing is not required to be performed in the REFUELING SHUTDOWN mode.

TS 4.11 Basis The term "refueling shutdowns" used to note the time period for the performance of certain safety injection system tests is revised to read "unit outages" instead to avoid confusion with an actual specific unit mode requirement that was not intended.

4 of 7

SPECIFIC CHANGES (continued}

TS 4.12.A.2, 3, 6b, 7b, 8b, and 9b The surveillance frequencies specified for various auxiliary ventilation exhaust filter train tests are "At least once per refueling cycle" or "At least once per refueling cycle, i.e., approximately 18 months" or a slight variation thereof. The surveillance frequencies for these various tests are revised to "once per 18 months."

TS 4.12.A.5 A typographical error is corrected. The last sentence of this specification ends with the words, "... and at the center of each carbon filters." The word "filters" is revised to "filter" for agreement with the singular modifier "each."

TS 4.17.C.1 The surveillance frequency specified for snubber functional testing is "At least once per 18 months during shutdown."

The surveillance frequency for this testing is revised to "Once per 18 months."

TS 4.17.F.1 This specification is revised to correct the statement that the records of service life of each snubber are maintained as required by Specification 6.5.B.9.

Specification 6.5 addressed Station Operating Records retention requirements but was recently deleted from the Technical Specifications by Amendments 211.

Record retention requirements are now contained in the Virginia Electric and Power Company Operational Quality Assurance Program Topical Report (QA Topical Report). The reference to Specification 6.5 in Specification 4.17.F.1 was inadvertently left unchanged during preparation of the previous Technical Specification change request to relocate the station operating records retention requirements to the bA Topical Report. Specification 4.17.F.1 will now reference the QA Topical Report for snubber service life records maintenance.

TS Bases 4.17 The discussion regarding snubber functional testing is revised to read "once per 18 months" rather than "during plant shutdowns at 18 month intervals."

5 of 7

e SPECIFIC CHANGES (continued)

TS 4.20.A.1.b, 3.b, 5.b, 7.b, and 9.b The surveillance frequency specified for various control room air filtration system tests is "At least once per refueling cycle, i.e., approximately every eighteen months." The surveillance frequency for these various tests is revised to "Once per 18 months."

The refueling interval surveillance requirements in Technical Specification 4.18, Fire Detection and Protection System Surveillance, are not being revised in this proposed change request.

A Technical Specifications change request has been previously submitted to the NRC that relocates TS 4.18 surveillance requirements from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR). Any required changes to this section will be appropriately addressed in a subsequent revision to the UFSAR.

SAFETY SIGNIFICANCE The proposed change updates the Technical Specifications to clarify the refueling interval surveillance frequencies provided in Section 4, Surveillance Requirements. The change does not increase the existing refueling interval nor the allowable adjustment and is consistent with NUREG-1431 Revision 1.

Since the time interval to perform surveillances is not being increased, there is no effect on the equipment being tested (e.g., instrument drift) as a result of the proposed Technical Specifications change.

Therefore, the proposed change is administrative in nature and has no effect on system/component operability.

The surveillance tests will continue to be performed in the required unit mode to ensure plant safety is not compromised. The initial conditions and any unit restrictions required for the performance of each surveillance test are properly addressed and controlled by the applicable surveillance test procedures. Furthermore, the removal of risk significant equipment from service for surveillance testing is appropriately reviewed against the on-line maintenance risk matrix to assure that risk is minimized. Also, surveillances must be performed within the allowed* outage times specified for the affected system/components in the applicable Technical Specifications which have been previously considered and determined to be acceptable.

The probability of an accident or equipment malfunction is not increased as a result of this Technical Specifications change request since surveillance intervals are being clarified, not changed, and will continue to validate system/component availability and performance. The consequences of an accident previously evaluated are not increased since station operations are not being changed, and no physical modifications are being made to plant systems or components. A new or different type of accident is not being 6 of 7

~I

SAFETY SIGNIFICANCE (continued) created since the surveillances will continue to be performed in the applicable unit mode as required to ensure proper system/component operations.

The margin of safety is not reduced since the surveillances will continue to ensure system/component performance as assumed in the existing safety analyses. Therefore, this administrative change to Technical Specifications has no impact on safety and does not result in an unreviewed safety question.

7 of 7

Retrieved from "https://kanterella.com/w/index.php?title=ML18153A345&oldid=4986547"