ML15021A130

Surry Power Station Units 1 and 2 - Proposed License Amendment Request Technical Specifications Surveillance Requirement and Basis Revisions for Generic Letter 2008-01 (Gas Accumulation)

ML15021A130
Person / Time
Site:	Surry
Issue date:	01/14/2015
From:	Sartain M D Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-485, GL-08-001
Download: ML15021A130 (26)

Text

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261JAN 14 20151 OCFR50.90 U. S. Nuclear Regulatory Commission Serial No.: 14-485Attention:

Document Control Desk SPS/LIC-CGL:

ROWashington, DC 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNITS 1 AND 2PROPOSED LICENSE AMENDMENT REQUESTTECHNICAL SPECIFICATIONS SURVEILLANCE REQUIREMENT AND BASISREVISIONS FOR GENERIC LETTER 2008-01 (GAS ACCUMULATION)

Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) issubmitting a license amendment request to add a Technical Specification (TS)Surveillance Requirement (SR) [TS 4.11 .C.5.d] to verify the Safety Injection (SI) Systemlocations susceptible to gas accumulation are sufficiently filled with water and to provideallowances which permit performance of the verification.

The change is being made toaddress the concerns discussed in Generic Letter 2008-01, "Managing GasAccumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."

The proposed amendment is consistent with Technical Specification Task Force (TSTF) Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, ManagingGas Accumulation."

By letter dated June 8, 2010 (Serial No.10-304),

Dominioncommitted to evaluate the NRC-approved TSTF traveler for applicability to Surry Units 1and 2 and, if a license amendment was determined to be necessary, to submit a licenseamendment within one year of NRC approval of the TSTF traveler.

Attachment 1 provides a discussion and assessment of the proposed change. Themarked-up and proposed pages for the TS and TS Bases are provided in Attachments 2and 3, respectively.

The TS Bases changes are provided for NRC information only.We have evaluated the proposed amendment and have determined that it does notinvolve a significant hazards consideration as defined in 10 CFR 50.92. The basis forthis determination is included in Attachment

1. We have also determined that operation with the proposed change will not result in any significant increase in the amount ofeffluents that may be released offsite or any significant increase in individual orcumulative occupational radiation exposure.

Therefore, the proposed amendment iseligible for categorical exclusion from an environmental assessment as set forth in10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed Serial No. 14-485Docket Nos. 50-280/281 Page 2 of 3change. The proposed TS change has been reviewed and approved by the FacilitySafety Review Committee.

Dominion requests approval of the proposed change by January 30, 2016 with a60-day implementation period.Should you have any questions or require additional information, please contactMr. Gary D. Miller at (804) 273-2771.

Respectfully, Mark D. SartainVice President

-Nuclear Engineering Commitments contained in this letter: NoneAttachments:

1. Discussion of Change2. Marked-up Technical Specifications and Bases Pages3. Proposed Technical Specifications and Bases PagesSTATE OF CONNECTICUT COUNTY OF NEW LONDONThe foregoing document was acknowledged before me, in and for the County and Stateaforesaid, today by Mr. Mark D. Sartain, who is Vice President

-Nuclear Engineering, ofVirginia 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 thestatements in the document are true to the best of his knowledge and belief.Acknowledged before me this day of 2JFAqAIUR 2015.My Commission Expires:

/ "Ce , /THOMAS CLEARY _________

NOTARY PUBLIC Notary PublicMY COMMISSION EXPIRESFEBRUARY 28, 2016 Serial No. 14-485Docket Nos. 50-280/281 Page 3 of 3cc: U.S. Nuclear Regulatory Commission

-Region IIMarquis One Tower245 Peachtree Center Avenue, NE Suite 1200Atlanta, GA 30303-1257 State Health Commissioner Virginia Department of HealthJames Madison Building

-7th floor109 Governor StreetSuite 730Richmond, VA 23219Ms. K. R. Cotton GrossNRC Project Manager-SurryU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager-North AnnaU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station Serial No. 14-485Docket Nos. 50-280/281 Attachment IDISCUSSION OF CHANGEVirginia Electric and Power Company(Dominion)

Surry Station Units I and 2 Serial No. 14-485Docket Nos. 50-280/281 Attachment IPage 1 of 6DISCUSSION OF CHANGE1.0 DESCRIPTION The proposed change adds a Technical Specification (TS) Surveillance Requirement (SR) [TS 4.11.C.5.d]

to verify the Safety Injection (SI) System locations susceptible togas accumulation are sufficiently filled with water and to provide allowances whichpermit performance of the verification.

The change is being made to address theconcerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation inEmergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."

The proposed amendment is consistent with TSTF-523, Revision 2, "GenericLetter 2008-01, Managing Gas Accumulation."

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Virginia Electric and Power Company (Dominion) has reviewed the model safetyevaluation, dated January 15, 2014, as part of the Federal Register Notice ofAvailability.

This review included a review of the NRC staff's evaluation, as well as theinformation provided in TSTF-523.

As described in the subsequent paragraphs, Dominion has concluded that the justifications presented in the TSTF-523 proposal andthe model safety evaluation prepared by the NRC staff are applicable to Surry PowerStation (SPS) Units 1 and 2 and justify this amendment for the incorporation of thechanges into the SPS Units 1 and 2 TS.2.2 Optional Changes and Variations Dominion is proposing deviations from the TS changes described in TSTF-523, Revision

2. The deviations are as follows:1. Consistent with the SPS Units 1 and 2 evaluations performed to address theconcerns identified in Generic Letter 2008-01, as discussed in Dominion letterSerial No. 08-0013B, dated October 14, 2008 (ML082890094),

Dominion isproposing a SR for the only system that is susceptible to gas accumulation (i.e.,the SI System).

For the reasons noted below, SRs will not be incorporated forthe following systems:* TS 3.4 and TS 4.5 Spray Systems (ITS 3.6.6.D and E)The Containment Spray (CS) System (including the chemical additional subsystem) is maintained sufficiently full from the refueling water storage tank Serial No. 14-485Docket Nos. 50-280/281 Attachment 1Page 2 of 6(RWST) to the normally closed discharge header isolation valves. Theremainder of the piping, which includes the vertical headers and the sprayrings, are maintained dry. The quarterly pump operability surveillances ensure adequate water volume is pumped through the suction and discharge piping at a velocity to adequately sweep any gas from the water filled systempiping. There are no identified gas intrusion mechanisms for this system.Therefore, since the CS piping is free of potential gas voids, a routinesurveillance to preclude gas accumulation by verifying the CS piping issufficiently filled with water is unnecessary.

The Recirculation Spray (RS) System piping is not maintained water filled bydesign. The pump and piping fill and self-vent during the course of a loss ofcoolant event and initial system operation.

The RS System will only actuatebased on specific actuation signals which will ensure there is adequate wateravailable to meet net positive suction head (NPSH) requirements.

Since theRS System is maintained dry and is designed to fill and vent, there is noidentified gas intrusion mechanism.

Consequently, a routine surveillance topreclude gas accumulation by verifying the RS piping is sufficiently filled withwater is unnecessary.

• TS 3.5 Residual Heat Removal System (ITS 3.4.6, 3.4.7, and 3.4.8)The Residual Heat Removal (RHR) System is located entirely insidecontainment, is not safety related but has special regulatory considerations (NSQ), and does not serve a dual function as Low Head Safety Injection (LHSI). The RHR System is an NSQ system because the RHR System isrequired to provide decay heat removal:

1) following an Appendix R event,2) when the units are in cold shutdown, and 3) when cooling units from hotshutdown to cold shutdown conditions following a hurricane.

The system isisolated and maintained sufficiently full of water when the system is not inoperation.

Based on a review of system design information, including pipingand instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations, as supplemented by system walk downs, theRHR System is not susceptible to gas intrusion, except primarily fromSI Accumulator line back leakage through the RHR discharge motor operatedvalves. This condition would be identified and mitigated prior to placing theRHR System in service.

Thus, the piping in the RHR System will remainsufficiently full during standby.

Once placed in service, RHR System flowvelocities during normal cooldown are sufficient to sweep any gas voids thatmay have remained in local high points. Controlling RHR System operating flow rates, with the consideration to limiting inlet conditions and ReactorCoolant System (RCS) level, prevents vortexing and air ingestion into theoperating RHR pump and piping. Thus, the piping in the RHR System willremain sufficiently full of water during standby and normal system operation, Serial No. 14-485Docket Nos. 50-280/281 Attachment 1Page 3 of 6and periodic monitoring for gas accumulation or intrusion is not required.

Consequently, a routine surveillance to verify the RHR System pipinglocations susceptible to gas accumulation are sufficiently filled with water isunnecessary.

The TS Basis Sections for the Spray Systems and RHR System are beingrevised to address the importance of gas management and system operability.

2. The surveillance frequencies for the portions of the SI System susceptible to gasaccumulation addressed by TS 4.11.C.5.d will be consistent with the existingSurry gas management program.

Currently, the High Head Safety Injection (HHSI) piping and the LHSI piping locations susceptible to gas accumulation aremonitored quarterly and when directed by engineering in accordance with theexisting Gas Accumulation Monitoring Plan. These frequencies will be controlled by the Surveillance Frequency Control Program after the surveillance requirement is incorporated into the TS.3. The SPS Units 1 and 2 TS use different numbering and title conventions than theStandard Technical Specifications on which TSTF-523 is based. Specifically, thefollowing TS are numbered and titled differently:

SPS 1 and 2 TS number and title ITS TS number and title3.3 Safety Injection Systems 3.5.2 ECCS -Operating 3.5.3 ECCS -Shutdown3.4 Spray Systems 3.6.6.D Quench Spray(Basis only changes) 3.6.6.E Recirculation Spray3.4.6 RCS Loops -MODE 43.5 Residual Heat Removal System 3.4.7 RCS Loops -MODE 5, Loops Filled(Basis only changes) 3.4.8 RCS Loops -MODE 5, Loops NotFilledThese TS numbering and title differences are administrative and do not affect theapplicability of TSTF-523 to the SPS Units 1 and 2 TS.4. The SPS Units 1 and 2 TS currently do not include Surveillance Requirements revised by TSTF-523.

This difference does not affect the applicability of TSTF-523 to the SPS TS.

Serial No. 14-485Docket Nos. 50-280/281 Attachment 1Page 4 of 63.0 REGULATORY ANALYSIS3.1 Applicable Regulatory Requirements The regulations in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR)Part 50 or similar plant-specific principal design criteria provide design requirements.

Appendix B to 10 CFR Part 50, the TSs, and the licensee quality assurance programsprovide operating requirements.

TSTF-523 and model safety evaluation discuss the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC).The Construction Permits for SPS Units I and 2 were issued prior to May 21, 1971;consequently, SPS Units 1 and 2 were not subject to current GDC requirements (SECY-92-223, dated September 18,1992).

SPS UFSAR Section 1.4 "Compliance withCriteria,"

provides an assessment against the 10 CFR 50, Appendix A, General DesignCriteria for Nuclear Power Plants, published in 1967 (Draft GDC). A review hasdetermined that the SPS plant-specific requirements are sufficiently similar to theAppendix A, GDC as related to the proposed change. Therefore, the proposed changeis applicable to SPS Units 1 and 2.3.2 No Significant Hazards Consideration Determination Virginia Electric and Power Company (Dominion) requests adoption of TSTF-523, Rev. 2, "Generic Letter 2008-01, Managing Gas Accumulation,"

which is an approvedchange to the Standard Technical Specifications (STS), into the Surry Power StationUnits 1 and 2 Technical Specifications (TS). The proposed change adds a Surveillance Requirement to verify that the Safety Injection (SI) System locations susceptible to gasaccumulation are sufficiently filled with water and to provide allowances which permitperformance of the verification.

Dominion has evaluated whether a significant hazards consideration is involved with theproposed amendment by focusing on the three standards set forth in 10 CFR 50.92,"Issuance of amendment,"

as discussed below:1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response:

No.The proposed change adds a Surveillance Requirement (SR) that requiresverification that the SI System is not rendered inoperable due to accumulated gasand to provide allowances which permit performance of the revised verification.

Gasaccumulation in the SI System is not an initiator of any accident previously evaluated.

As a result, the probability of any accident previously evaluated is not Serial No. 14-485Docket Nos. 50-280/281 Attachment 1Page 5 of 6significantly increased.

The proposed SR ensures that the SI System continues tobe capable of performing its assumed safety function and is not rendered inoperable due to gas accumulation.

Thus, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in theprobability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind ofaccident from any accident previously evaluated?

Response:

No.The proposed change adds a SR that requires verification that the SI System is notrendered inoperable due to accumulated gas and to provide allowances whichpermit performance of the revised verification.

The proposed change does notinvolve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

Inaddition, the proposed change does not impose any new or different requirements that could initiate an accident.

The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change adds a SR that requires verification that the SI System is notrendered inoperable due to accumulated gas and to provide allowances whichpermit performance of the revised verification.

The proposed change adds a newrequirement to manage gas accumulation to ensure the SI System is capable ofperforming its assumed safety functions.

The proposed SR is comprehensive andwill ensure that the assumptions of the safety analysis are protected.

The proposedchange does not adversely affect any current plant safety margins or the reliability ofthe equipment assumed in the safety analysis.

Therefore, there are no changesbeing made to any safety analysis assumptions, safety limits, or limiting safetysystem settings that would adversely affect plant safety as a result of the proposedchange.Therefore, the proposed change does not involve a significant reduction in a marginof safety.

Serial No. 14-485Docket Nos. 50-280/281 Attachment 1Page 6 of 6Based on the above, Dominion concludes that the proposed change presents nosignificant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and,accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed revision will change a requirement with respect to installation or use of afacility component located within the restricted area, as defined in 10 CFR 20, or willchange an inspection or surveillance requirement.

However, the proposed change doesnot involve (i) a significant hazards consideration, (ii) a significant change in the types ora significant increase in the amounts of any effluent that may be released

offsite, or (iii)a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b),

noenvironmental impact statement or environmental assessment need be prepared inconnection with the proposed change.

Serial No. 14-485Docket Nos. 50-280/281 Attachment 2MARKED-UP TECHNICAL SPECIFICATIONS AND BASES PAGES(Basis Changes are for NRC Information Only)Virginia Electric and Power Company(Dominion)

Surry Station Units I and 2 TS 3.3-3maintenance provided that not more than one valve has power restored, andthe testing and maintenance is completed and power removed within4 hours.3. With one safety injection subsystem inoperable, restore the inoperable sub-system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or place the reactor in HOTSHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.C. If the requirements of specification 3.3.A are not satisfied as allowed bySpecification 3.3.B, the reactor shall be placed in COLD SHUTDOWN in thefollowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.BasisThe normal procedure for starting the reactor is, first, to heat the reactor coolant to nearoperating temperature by running the reactor coolant pumps. The reactor is then madecritical by withdrawing control rods and/or diluting boron in the coolant.

With this modeof startup the Safety Injection System is required to be OPERABLE as specified.

DuringLOW POWER PHYSICS TESTS there is a negligible amount of energy stored in thesystem. Therefore, an accident comparable in severity to the Design Basis Accident is notpossible, and the full capacity of the Safety Injection System would not be necessary.

The OPERABLE status of the subsystems is to be demonstrated by periodic tests, detailed

}in TS Section 4.11. A large fraction of these tests are performed while the reactor isoperating in the power range. If a subsystem is found to be inoperable, it will be possiblein most cases to effect repairs and restore the subsystem to full operability within arelatively short time. A subsystem being inoperable does not negate the ability of thesystem to perform its function, but it reduces the redundancy provided in the reactordesign and thereby limits the ability to tolerate additional subsystem failures.

In somecases, additional components (i.e., charging pumps) are installed to allow a component tobe inoperable without affecting system redundancy.

Management of gas voids is important to Safety Injection System operability.

Amendment Nos. 4-99 and 1-99 TS 3.4-405-34 In addition to supplying water to the Containment Spray System, the refueling waterstorage tank is also a source of water for safety injection following an accident.

This wateris borated to a concentration which assures reactor shutdown by approximately 5 percentAk/k when all control rods assemblies are inserted and when the reactor is cooled down forrefueling.

InsrtReferences UFSAR Section 4UFSAR Section 6.3.1UFSAR Section 6.3.1UFSAR Section 6.3.1UFSAR Section 6.3.1UFSAR Section 14.5.2UFSAR Section 14.5.5Reactor Coolant SystemContainment Spray Subsystem Recirculation Spray Pumps and CoolersRefueling Water Chemical Addition TankRefueling Water Storage TankDesign Basis AccidentContainment Transient AnalysisAmendment Nos. 1-99-and TS 3.5-21. One residual heat removal pump may be out of service, provided immediate attention isdirected to making repairs.2. One residual heat removal heat exchanger may be out of service, provided immediate attention is directed to making repairs.BasisThe Residual Heat Removal System is required to bring the Reactor Coolant System fromconditions of approximately 350'F and pressures between 400 and 450 psig to cold shutdown 4-,,'conditions.

Heat removal at greater temperatures is by the Steam and Power Conversion System.The Residual Heat Removal System is provided with two pumps and two heat exchangers.

If oneof the two pumps and/or one of the two heat exchangers is not operative, safe operation of the unitis not affected;

however, the time for cooldown to cold shutdown conditions is extended.

The NRC requires that the series motorized valves in the line connecting the RHRS and RCS beprovided with pressure interlocks to prevent them from opening when the reactor coolant systemis at pressure.

References eBFSAR Section 9.3 -Residual Heat Removal SystemAmendments No.-6-7-&

67-TS 4.11-204-29-112. Verifying:

For information onlya. The boron concentration of the accumulator solution is within specified limits,andb. The boron concentration of the accumulator solution within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after eachsolution volume increase of greater than or equal to 1% of tank volume.Note: Surveillance 4.11 .B.2.b is not required when the volume increase makeupsource is the RWST.C. Each Safety Injection Subsystem shall be demonstrated OPERABLE at the frequency specified in the Surveillance Frequency Control Program unless otherwise noted belowby:1. Verifying, that on recirculation flow, each low head safety injection pump performssatisfactorily when tested in accordance with the Inservice Testing Program.2. Verifying that each charging pump performs satisfactorily when tested in accordance with the Inservice Testing Program.3. Verifying that each motor-operated valve in the safety injection flow path performssatisfactorily when tested in accordance with the Inservice Testing Program.4. Prior to POWER OPERATION by:a. Verifying that the following motor operated valves are blocked open byde-energizing AC power to the valves motor operator and tagging the breaker inthe off position:

Unit 1 Unit 2MOV-1890C MOV-2890C

b. Verifying that the following motor operated valves are blocked closed byde-energizing AC power to the valves motor operator and the breaker is locked,sealed or otherwise secured in the off position:

Unit 1 Unit 2MOV-1869A MOV-2869A MOV-1869B MOV-2869B MOV- 1890A MOV-2890A MOV-1890B MOV-2890B Amendment Nos. 273 and 272 TS 4.11-30,4-29-f fc. Power may be restored to any valve or breaker referenced in Specifications 4.11 .C.4.a and 4.11 .C.4.b for the purpose of testing or maintenance providedthat not more than one valve has power restored at one time, and the testing andmaintenance is completed and power removed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.5. Verifying:

Va. That each automatic valve capable of receiving a safety injection signal,actuates to its correct position upon receipt of a safety injection test signal. Thecharging and low head safety injection pumps may be immobilized for this test.b. That each charging pump and safety injection pump circuit breaker actuates toits correct position upon receipt of a safety injection test signal. The chargingand low head safety injection pumps may be immobilized for this test.c. By visual inspection that the low head safety injection containment sump ,/components are not restricted by debris and show no evidence of structural distress or abnormal corrosion.

BasisA d. That the Safety Injection System locations susceptible to gas accumulation arelýsufficiently filled with water.Complete system tests cannot be performed when the reactor is operating because a safetyinjection signal causes containment isolation.

The method of assuring operability of thesesystems is therefore to combine system tests to be performed during unit outages, withmore frequent component tests, which can be performed during reactor operation.

Amendment Nos. =ý- and 25 TS 4.11-4The system tests demonstrate proper automatic operation of the Safety Injectiontz' System. A test signal is applied to initiate automatic operation action andverification is made that the components receive the safety injection signal in theproper sequence.

The test may be performed with the pumps blocked from starting.

The test demonstrates the operation of the valves, pump circuit breakers, andautomatic circuitry.

During reactor operation, the instrumentation which is depended on to initiatesafety injection is checked periodically, and the initiating circuits are tested inaccordance with Specification 4.1. In addition, the active components (pumps andvalves) are to be periodically tested to check the operation of the starting circuitsand to verify that the pumps are in satisfactory running order. The test interval isdetermined in accordance with the Inservice Testing Program.

The accumulators are a passive safeguard.

Periodic inspections of containment sump components ensure that the components are unrestricted and stay in proper operating condition.

The Surveillance Frequency Lis controlled under the Surveillance Frequency Control Program.References UFSAR Section 6.2, Safety Injection SystemAmendment Nos. 2-7-3 and 2-2 Serial No. 14-485Docket Nos. 50-280/281 Insert A -3.4 Spray System BasisManagement of gas voids is important to the operability of the Spray Systems.

Basedon a review of system design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations, assupplemented by system walk downs, the Containment Spray Subsystem, InsideRecirculation Spray Subsystem, and Outside Recirculation Spray Subsystem are notsusceptible to gas intrusion.

Once the piping in the Spray Systems is procedurally filledand placed in service for normal operation, no external sources of gas accumulation orintrusion have been identified for these systems that would affect spray systemoperation or performance.

Thus, the piping in the Spray Systems will remain sufficiently full during normal operation, and periodic monitoring for gas accumulation or intrusion isnot required.

Insert B -3.5 Residual Heat Removal BasisManagement of gas voids is important to RHR System operability.

Based on a reviewof system design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations, as supplemented by systemwalk downs, the RHR System is not susceptible to gas intrusion, except primarily fromSafety Injection Accumulator line back leakage through the RHR discharge motoroperated valves. If this condition were to occur, it would be identified and mitigated prior to placing the system in service.

Once placed in service, RHR System velocities during normal cooldown are sufficient to sweep any gas voids that may have remainedin local high points. Controlling RHR System operating flow rates, with theconsideration to limiting inlet conditions and RCS level, prevents vortexing and airingestion into the operating RHR pump and piping. Thus, the piping in the RHR Systemwill remain sufficiently full of water during standby and normal system operation, andperiodic monitoring for gas accumulation or intrusion is not required.

Insert C -TS 4.11 Safety Injection Subsystems BasisECCS piping and components have the potential to develop voids and pockets ofentrained gases. Preventing and managing gas intrusion and accumulation arenecessary for proper operation of the ECCS and may also prevent water hammer,pump cavitation, and pumping of noncondensible gas into the reactor vessel.Selection of SI System locations susceptible to gas accumulation is based on a reviewof system design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations.

The design review wassupplemented by system walk downs to validate the system high points and to confirmthe location and orientation of important components that can become sources of gas orcould otherwise cause gas to be trapped or difficult to remove during systemmaintenance or restoration.

Susceptible locations depend on plant and systemconfigurations, such as stand-by versus operating conditions.

Serial No. 14-485Docket Nos. 50-280/281 The SI System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

Ifaccumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump),the surveillance is not met. If it is determined by subsequent evaluation that the SISystem is not rendered inoperable by the accumulated gas (i.e., the system issufficiently filled with water), the surveillance may be declared met. Accumulated gasshould be eliminated or brought within the acceptance criteria limits.SI System locations susceptible to gas accumulation are monitored and, if gas is found,the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due toradiological or environmental conditions, the plant configuration, or personnel safety.For these locations, alternative methods (e.g., operating parameters, remotemonitoring) may be used to monitor the susceptible location.

Monitoring is not requiredfor susceptible locations where the maximum potential accumulated gas void volumehas been evaluated and determined to not challenge system operability.

The accuracyof the method used for monitoring the susceptible locations and trending of the resultsshould be sufficient to assure system operability during the surveillance interval.

System vent flow paths opened under administrative control are permitted to performthe surveillance.

The administrative control will be appropriately documented (e.g., proceduralized) and will include stationing a dedicated individual at the systemvent flow path who is in continuous communication with the operators in the controlroom. This individual will have a method to rapidly close the system vent flow path ifdirected.

The monitoring frequency takes into consideration the gradual nature of gasaccumulation in the SI Subsystem piping and the procedural controls governing systemoperation and is controlled by the Surveillance Frequency Control Program.

Thesurveillance frequency may vary by each location's susceptibility to gas accumulation.

Serial No. 14-485Docket Nos. 50-280/281 Attachment 3PROPOSED TECHNICAL SPECIFICATIONS AND BASES PAGES(Basis Changes are for NRC Information Only)Virginia Electric and Power Company(Dominion)

Surry Station Units 1 and 2 TS 3.3-3maintenance provided that not more than one valve has power restored, andthe testing and maintenance is completed and power removed within4 hours.3. With one safety injection subsystem inoperable, restore the inoperable sub-system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or place the reactor in HOTSHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.C. If the requirements of Specification 3.3.A are not satisfied as allowed bySpecification 3.3.B, the reactor shall be placed in COLD SHUTDOWN in thefollowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.BasisThe normal procedure for starting the reactor is, first, to heat the reactor coolant to nearoperating temperature by running the reactor coolant pumps. The reactor is then madecritical by withdrawing control rods and/or diluting boron in the coolant.

With this modeof startup the Safety Injection System is required to be OPERABLE as specified.

DuringLOW POWER PHYSICS TESTS there is a negligible amount of energy stored in thesystem. Therefore, an accident comparable in severity to the Design Basis Accident is notpossible, and the full capacity of the Safety Injection System would not be necessary.

Management of gas voids is important to Safety Injection System operability.

TheOPERABLE status of the subsystems is to be demonstrated by periodic tests, detailed inTS Section 4.11. A large fraction of these tests are performed while the reactor isoperating in the power range. If a subsystem is found to be inoperable, it will be possiblein most cases to effect repairs and restore the subsystem to full operability within arelatively short time. A subsystem being inoperable does not negate the ability of thesystem to perform its function, but it reduces the redundancy provided in the reactordesign and thereby limits the ability to tolerate additional subsystem failures.

In somecases, additional components (i.e., charging pumps) are installed to allow a component tobe inoperable without affecting system redundancy.

Amendment Nos.

TS 3.4-4In addition to supplying water to the Containment Spray System, the refueling waterstorage tank is also a source of water for safety injection following an accident.

This wateris borated to a concentration which assures reactor shutdown by approximately 5 percentAk/k when all control rods assemblies are inserted and when the reactor is cooled down forrefueling.

Management of gas voids is important to the operability of the Spray Systems.

Based on areview of system design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations, as supplemented bysystem walk downs, the Containment Spray Subsystem, Inside Recirculation SpraySubsystem, and Outside Recirculation Spray Subsystem are not susceptible to gasintrusion.

Once the piping in the Spray Systems is procedurally filled and placed in servicefor normal operation, no external sources of gas accumulation or intrusion have beenidentified for these systems that would affect spray system operation or performance.

Thus, the piping in the Spray Systems will remain sufficiently full during normaloperation, and periodic monitoring for gas accumulation or intrusion is not required.

References UFSAR Section 4UFSAR Section 6.3.1UFSAR Section 6.3.1UFSAR Section 6.3.1UFSAR Section 6.3.1UFSAR Section 14.5.2UFSAR Section 14.5.5Reactor Coolant SystemContainment Spray Subsystem Recirculation Spray Pumps and CoolersRefueling Water Chemical Addition TankRefueling Water Storage TankDesign Basis AccidentContainment Transient AnalysisAmendment Nos.

TS 3.5-21. One residual heat removal pump may be out of service, provided immediate attention isdirected to making repairs.2. One residual heat removal heat exchanger may be out of service, provided immediate attention is directed to making repairs.BasisThe Residual Heat Removal System is required to bring the Reactor Coolant System fromconditions of approximately 350'F and pressures between 400 and 450 psig to cold shutdownconditions.

Heat removal at greater temperatures is by the Steam and Power Conversion System.The Residual Heat Removal System is provided with two pumps and two heat exchangers.

If oneof the two pumps and/or one of the two heat exchangers is not operative, safe operation of the unitis not affected;

however, the time for cooldown to cold shutdown conditions is extended.

The NRC requires that the series motorized valves in the line connecting the RHRS and RCS beprovided with pressure interlocks to prevent them from opening when the reactor coolant systemis at pressure.

Management of gas voids is important to RHR System operability.

Based on a review of systemdesign information, including piping and instrumentation

drawings, isometric

drawings, plan andelevation

drawings, and calculations, as supplemented by system walk downs, the RHR System isnot susceptible to gas intrusion, except primarily from Safety Injection Accumulator line backleakage through the RHR discharge motor operated valves. If this condition were to occur, itwould be identified and mitigated prior to placing the system in service.

Once placed in service,RHR System velocities during normal cooldown are sufficient to sweep any gas voids that mayhave remained in local high points. Controlling RHR System operating flow rates, with theconsideration to limiting inlet conditions and RCS level, prevents vortexing and air ingestion intothe operating RHR pump and piping. Thus, the piping in the RHR System will remain sufficiently full of water during standby and normal system operation, and periodic monitoring for gasaccumulation or intrusion is not required.

References FSAR Section 9.3 -Residual Heat Removal SystemAmendments Nos.

TS 4.11-3c. Power may be restored to any valve or breaker referenced in Specifications 4.11 .C.4.a and 4.11 .C.4.b for the purpose of testing or maintenance providedthat not more than one valve has power restored at one time, and the testing andmaintenance is completed and power removed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.5. Verifying:

a. That each automatic valve capable of receiving a safety injection signal,actuates to its correct position upon receipt of a safety injection test signal. Thecharging and low head safety injection pumps may be immobilized for this test.b. That each charging pump and safety injection pump circuit breaker actuates toits correct position upon receipt of a safety injection test signal. The chargingand low head safety injection pumps may be immobilized for this test.c. By visual inspection that the low head safety injection containment sumpcomponents are not restricted by debris and show no evidence of structural distress or abnormal corrosion.

d. That the Safety Injection System locations susceptible to gas accumulation aresufficiently filled with water.BasisComplete system tests cannot be performed when the reactor is operating because a safetyinjection signal causes containment isolation.

The method of assuring operability of thesesystems is therefore to combine system tests to be performed during unit outages, withmore frequent component tests, which can be performed during reactor operation.

Amendment Nos.

TS 4.11-4The system tests demonstrate proper automatic operation of the Safety Injection (SI) System. A test signal is applied to initiate automatic operation action andverification is made that the components receive the safety injection signal in theproper sequence.

The test may be performed with the pumps blocked from starting.

The test demonstrates the operation of the valves, pump circuit breakers, andautomatic circuitry.

During reactor operation, the instrumentation which is depended on to initiatesafety injection is checked periodically, and the initiating circuits are tested inaccordance with Specification 4.1. In addition, the active components (pumps andvalves) are to be periodically tested to check the operation of the starting circuitsand to verify that the pumps are in satisfactory running order. The test interval isdetermined in accordance with the Inservice Testing Program.

The accumulators are a passive safeguard.

ECCS piping and components have the potential to develop voids and pockets ofentrained gases. Preventing and managing gas intrusion and accumulation arenecessary for proper operation of the ECCS and may also prevent water hammer,pump cavitation, and pumping of noncondensible gas into the reactor vessel.Selection of SI System locations susceptible to gas accumulation is based on areview of system design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations.

Thedesign review was supplemented by system walk downs to validate the system highpoints and to confirm the location and orientation of important components thatcan become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations dependon plant and system configurations, such as stand-by versus operating conditions.

The SI System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for thesusceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the surveillance is not met. If it is determined by subsequent evaluation Amendment Nos.

TS 4.11-4a Ithat the SI System is not rendered inoperable by the accumulated gas (i.e., thesystem is sufficiently filled with water), the surveillance may be declared met.Accumulated gas should be eliminated or brought within the acceptance criterialimits.SI System locations susceptible to gas accumulation are monitored and, if gas isfound, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the samegas intrusion mechanisms may be verified by monitoring a representative sub-set ofsusceptible locations.

Monitoring may not be practical for locations that areinaccessible due to radiological or environmental conditions, the plantconfiguration, or personnel safety. For these locations, alternative methods (e.g.,operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximumpotential accumulated gas void volume has been evaluated and determined to notchallenge system operability.

The accuracy of the method used for monitoring thesusceptible locations and trending of the results should be sufficient to assuresystem operability during the surveillance interval.

System vent flow paths opened under administrative control are permitted toperform the surveillance.

The administrative control will be appropriately documented (e.g., proceduralized) and will include stationing a dedicated individual at the system vent flow path who is in continuous communication withthe operators in the control room. This individual will have a method to rapidlyclose the system vent flow path if directed.

The monitoring frequency takes into consideration the gradual nature of gasaccumulation in the SI Subsystem piping and the procedural controls governing system operation and is controlled by the Surveillance Frequency Control Program.The surveillance frequency may vary by each location's susceptibility to gasaccumulation.

Periodic inspections of containment sump components ensure that the components are unrestricted and stay in proper operating condition.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.References UFSAR Section 6.2, Safety Injection SystemAmendment Nos.