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 COMPANY RICHMOND, VIRGINIA 23261 JAN 14 2015 1 OCFR50.90 U. S. Nuclear Regulatory Commission Serial No.: 14-485 Attention:

Document Control Desk SPS/LIC-CGL:

RO Washington, DC 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY 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)

Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) is submitting 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) System locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

The change is being made to address the concerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation 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, Managing Gas Accumulation." By letter dated June 8, 2010 (Serial No.10-304), Dominion committed to evaluate the NRC-approved TSTF traveler for applicability to Surry Units 1 and 2 and, if a license amendment was determined to be necessary, to submit a license amendment within one year of NRC approval of the TSTF traveler.Attachment 1 provides a discussion and assessment of the proposed change. The marked-up and proposed pages for the TS and TS Bases are provided in Attachments 2 and 3, respectively.

The TS Bases changes are provided for NRC information only.We have evaluated the proposed amendment and have determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. The basis for this 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 of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 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.14-485 Docket Nos. 50-280/281 Page 2 of 3 change. The proposed TS change has been reviewed and approved by the Facility Safety Review Committee.

Dominion requests approval of the proposed change by January 30, 2016 with a 60-day implementation period.Should you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.Respectfully, Mark D. Sartain Vice President

-Nuclear Engineering Commitments contained in this letter: None Attachments:

1. Discussion of Change 2. Marked-up Technical Specifications and Bases Pages 3. Proposed Technical Specifications and Bases Pages STATE OF CONNECTICUT COUNTY OF NEW LONDON The foregoing document was acknowledged before me, in and for the County and State aforesaid, today by Mr. Mark D. Sartain, who is Vice President

-Nuclear Engineering, 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 day of 2JFAqAIUR 2015.My Commission Expires: / "Ce , /THOMAS CLEARY _________NOTARY PUBLIC Notary Public MY COMMISSION EXPIRES FEBRUARY 28, 2016 Serial No.14-485 Docket Nos. 50-280/281 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission

-Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 State Health Commissioner Virginia Department of Health James Madison Building -7 th floor 109 Governor Street Suite 730 Richmond, VA 23219 Ms. K. R. Cotton Gross NRC Project Manager- Surry U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager- North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station Serial No.14-485 Docket Nos. 50-280/281 Attachment I DISCUSSION OF CHANGE Virginia Electric and Power Company (Dominion)

Surry Station Units I and 2 Serial No.14-485 Docket Nos. 50-280/281 Attachment I Page 1 of 6 DISCUSSION OF CHANGE

1.0 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 to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

The change is being made to address the concerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." The proposed amendment is consistent with TSTF-523, Revision 2, "Generic Letter 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 safety evaluation, dated January 15, 2014, as part of the Federal Register Notice of Availability.

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

As described in the subsequent paragraphs, Dominion has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC staff are applicable to Surry Power Station (SPS) Units 1 and 2 and justify this amendment for the incorporation of the changes 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 the concerns identified in Generic Letter 2008-01, as discussed in Dominion letter Serial No. 08-0013B, dated October 14, 2008 (ML082890094), Dominion is proposing 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 for the 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.14-485 Docket Nos. 50-280/281 Attachment 1 Page 2 of 6 (RWST) to the normally closed discharge header isolation valves. The remainder of the piping, which includes the vertical headers and the spray rings, 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 system piping. There are no identified gas intrusion mechanisms for this system.Therefore, since the CS piping is free of potential gas voids, a routine surveillance to preclude gas accumulation by verifying the CS piping is sufficiently filled with water is unnecessary.

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

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

Since the RS System is maintained dry and is designed to fill and vent, there is no identified gas intrusion mechanism.

Consequently, a routine surveillance to preclude gas accumulation by verifying the RS piping is sufficiently filled with water 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 inside containment, 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 is required 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 hot shutdown to cold shutdown conditions following a hurricane.

The system is isolated and maintained sufficiently full of water when the system is not in operation.

Based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations, as supplemented by system walk downs, the RHR System is not susceptible to gas intrusion, except primarily from SI Accumulator line back leakage through the RHR discharge motor operated valves. This condition would be identified and mitigated prior to placing the RHR System in service. Thus, the piping in the RHR System will remain sufficiently full during standby. Once placed in service, RHR System flow velocities during normal cooldown are sufficient to sweep any gas voids that may have remained in local high points. Controlling RHR System operating flow rates, with the consideration to limiting inlet conditions and Reactor Coolant System (RCS) level, prevents vortexing and air ingestion into the operating RHR pump and piping. Thus, the piping in the RHR System will remain sufficiently full of water during standby and normal system operation, Serial No.14-485 Docket Nos. 50-280/281 Attachment 1 Page 3 of 6 and periodic monitoring for gas accumulation or intrusion is not required.Consequently, a routine surveillance to verify the RHR System piping locations susceptible to gas accumulation are sufficiently filled with water is unnecessary.

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

2. The surveillance frequencies for the portions of the SI System susceptible to gas accumulation addressed by TS 4.11.C.5.d will be consistent with the existing Surry gas management program. Currently, the High Head Safety Injection (HHSI) piping and the LHSI piping locations susceptible to gas accumulation are monitored quarterly and when directed by engineering in accordance with the existing 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 the Standard Technical Specifications on which TSTF-523 is based. Specifically, the following TS are numbered and titled differently:

SPS 1 and 2 TS number and title ITS TS number and title 3.3 Safety Injection Systems 3.5.2 ECCS -Operating 3.5.3 ECCS -Shutdown 3.4 Spray Systems 3.6.6.D Quench Spray (Basis only changes) 3.6.6.E Recirculation Spray 3.4.6 RCS Loops -MODE 4 3.5 Residual Heat Removal System 3.4.7 RCS Loops -MODE 5, Loops Filled (Basis only changes) 3.4.8 RCS Loops -MODE 5, Loops Not Filled These TS numbering and title differences are administrative and do not affect the applicability 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.14-485 Docket Nos. 50-280/281 Attachment 1 Page 4 of 6 3.0 REGULATORY ANALYSIS 3.1 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 programs provide 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 with Criteria," provides an assessment against the 10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants, published in 1967 (Draft GDC). A review has determined that the SPS plant-specific requirements are sufficiently similar to the Appendix A, GDC as related to the proposed change. Therefore, the proposed change is 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 approved change to the Standard Technical Specifications (STS), into the Surry Power Station Units 1 and 2 Technical Specifications (TS). The proposed change adds a Surveillance Requirement to verify that the Safety Injection (SI) System locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

Dominion has evaluated whether a significant hazards consideration is involved with the proposed 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 or consequences of an accident previously evaluated?

Response:

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

Gas accumulation 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.14-485 Docket Nos. 50-280/281 Attachment 1 Page 5 of 6 significantly increased.

The proposed SR ensures that the SI System continues to be 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 the probability or consequences of an accident previously evaluated.

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

Response:

No.The proposed change adds a SR that requires verification that the SI System is not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification.

The proposed change does not involve 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.

In addition, 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 not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification.

The proposed change adds a new requirement to manage gas accumulation to ensure the SI System is capable of performing its assumed safety functions.

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

The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis.

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

Serial No.14-485 Docket Nos. 50-280/281 Attachment 1 Page 6 of 6 Based on the above, Dominion concludes that the proposed change presents no significant 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 a facility component located within the restricted area, as defined in 10 CFR 20, or will change an inspection or surveillance requirement.

However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Serial No.14-485 Docket Nos. 50-280/281 Attachment 2 MARKED-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 3.3-3 maintenance provided that not more than one valve has power restored, and the testing and maintenance is completed and power removed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.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 HOT SHUTDOWN 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 by Specification 3.3.B, the reactor shall be placed in COLD SHUTDOWN in the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.Basis The normal procedure for starting the reactor is, first, to heat the reactor coolant to near operating temperature by running the reactor coolant pumps. The reactor is then made critical by withdrawing control rods and/or diluting boron in the coolant. With this mode of startup the Safety Injection System is required to be OPERABLE as specified.

During LOW POWER PHYSICS TESTS there is a negligible amount of energy stored in the system. Therefore, an accident comparable in severity to the Design Basis Accident is not possible, 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 is operating in the power range. If a subsystem is found to be inoperable, it will be possible in most cases to effect repairs and restore the subsystem to full operability within a relatively short time. A subsystem being inoperable does not negate the ability of the system to perform its function, but it reduces the redundancy provided in the reactor design and thereby limits the ability to tolerate additional subsystem failures.

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

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

Amendment Nos. 4-99 and 1-99 TS 3.4-4 05-34-95-In addition to supplying water to the Containment Spray System, the refueling water storage tank is also a source of water for safety injection following an accident.

This water is borated to a concentration which assures reactor shutdown by approximately 5 percent Ak/k when all control rods assemblies are inserted and when the reactor is cooled down for refueling.

Insrt References UFSAR Section 4 UFSAR Section 6.3.1 UFSAR Section 6.3.1 UFSAR Section 6.3.1 UFSAR Section 6.3.1 UFSAR Section 14.5.2 UFSAR Section 14.5.5 Reactor Coolant System Containment Spray Subsystem Recirculation Spray Pumps and Coolers Refueling Water Chemical Addition Tank Refueling Water Storage Tank Design Basis Accident Containment Transient Analysis Amendment Nos. 1-99-and TS 3.5-2 1. One residual heat removal pump may be out of service, provided immediate attention is directed to making repairs.2. One residual heat removal heat exchanger may be out of service, provided immediate attention is directed to making repairs.Basis The Residual Heat Removal System is required to bring the Reactor Coolant System from conditions 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 one of the two pumps and/or one of the two heat exchangers is not operative, safe operation of the unit is 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 be provided with pressure interlocks to prevent them from opening when the reactor coolant system is at pressure.References eB FSAR Section 9.3 -Residual Heat Removal System Amendments No.-6-7-&

67-TS 4.11-2 04-29-11 2. Verifying:

For information only a. The boron concentration of the accumulator solution is within specified limits, and b. 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 each solution 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 makeup source 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 below by: 1. Verifying, that on recirculation flow, each low head safety injection pump performs satisfactorily 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 performs satisfactorily 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 by de-energizing AC power to the valves motor operator and tagging the breaker in the off position: Unit 1 Unit 2 MOV-1890C MOV-2890C b. Verifying that the following motor operated valves are blocked closed by de-energizing AC power to the valves motor operator and the breaker is locked, sealed or otherwise secured in the off position: Unit 1 Unit 2 MOV-1869A MOV-2869A MOV-1869B MOV-2869B MOV- 1890A MOV-2890A MOV-1890B MOV-2890B Amendment Nos. 273 and 272 TS 4.11-3 0,4-29-f f c. 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 provided that not more than one valve has power restored at one time, and the testing and maintenance 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:

V 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. The charging and low head safety injection pumps may be immobilized for this test.b. That each charging pump and safety injection pump circuit breaker actuates to its correct position upon receipt of a safety injection test signal. The charging and 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 safety injection signal causes containment isolation.

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

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

The test may be performed with the pumps blocked from starting.The test demonstrates the operation of the valves, pump circuit breakers, and automatic circuitry.

During reactor operation, the instrumentation which is depended on to initiate safety injection is checked periodically, and the initiating circuits are tested in accordance with Specification 4.1. In addition, the active components (pumps and valves) are to be periodically tested to check the operation of the starting circuits and to verify that the pumps are in satisfactory running order. The test interval is determined 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 L is controlled under the Surveillance Frequency Control Program.References UFSAR Section 6.2, Safety Injection System Amendment Nos. 2-7-3 and 2-2 Serial No.14-485 Docket Nos. 50-280/281 Insert A -3.4 Spray System Basis Management of gas voids is important to the operability of the Spray Systems. Based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations, as supplemented by system walk downs, the Containment Spray Subsystem, Inside Recirculation Spray Subsystem, and Outside Recirculation Spray Subsystem are not susceptible to gas intrusion.

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

Thus, the piping in the Spray Systems will remain sufficiently full during normal operation, and periodic monitoring for gas accumulation or intrusion is not required.Insert B -3.5 Residual Heat Removal Basis Management of gas voids is important to RHR System operability.

Based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations, as supplemented by system walk downs, the RHR System is not susceptible to gas intrusion, except primarily from Safety Injection Accumulator line back leakage through the RHR discharge motor operated 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 remained in local high points. Controlling RHR System operating flow rates, with the consideration to limiting inlet conditions and RCS level, prevents vortexing and air ingestion into the 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 gas accumulation or intrusion is not required.Insert C -TS 4.11 Safety Injection Subsystems Basis ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation are necessary 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 review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review was supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

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

Serial No.14-485 Docket 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.

If accumulated 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 SI System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the surveillance may be declared met. Accumulated gas should 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 to radiological or environmental conditions, the plant configuration, 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 maximum potential accumulated gas void volume has been evaluated and determined to not challenge system operability.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system operability during the surveillance interval.System vent flow paths opened under administrative control are permitted to perform 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 with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.The monitoring frequency takes into consideration the gradual nature of gas accumulation 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 gas accumulation.

Serial No.14-485 Docket Nos. 50-280/281 Attachment 3 PROPOSED 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 3.3-3 maintenance provided that not more than one valve has power restored, and the testing and maintenance is completed and power removed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.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 HOT SHUTDOWN 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 by Specification 3.3.B, the reactor shall be placed in COLD SHUTDOWN in the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.Basis The normal procedure for starting the reactor is, first, to heat the reactor coolant to near operating temperature by running the reactor coolant pumps. The reactor is then made critical by withdrawing control rods and/or diluting boron in the coolant. With this mode of startup the Safety Injection System is required to be OPERABLE as specified.

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

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

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 is operating in the power range. If a subsystem is found to be inoperable, it will be possible in most cases to effect repairs and restore the subsystem to full operability within a relatively short time. A subsystem being inoperable does not negate the ability of the system to perform its function, but it reduces the redundancy provided in the reactor design and thereby limits the ability to tolerate additional subsystem failures.

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

Amendment Nos.

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

This water is borated to a concentration which assures reactor shutdown by approximately 5 percent Ak/k when all control rods assemblies are inserted and when the reactor is cooled down for refueling.

Management of gas voids is important to the operability of the Spray Systems. Based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations, as supplemented by system walk downs, the Containment Spray Subsystem, Inside Recirculation Spray Subsystem, and Outside Recirculation Spray Subsystem are not susceptible to gas intrusion.

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

Thus, the piping in the Spray Systems will remain sufficiently full during normal operation, and periodic monitoring for gas accumulation or intrusion is not required.References UFSAR Section 4 UFSAR Section 6.3.1 UFSAR Section 6.3.1 UFSAR Section 6.3.1 UFSAR Section 6.3.1 UFSAR Section 14.5.2 UFSAR Section 14.5.5 Reactor Coolant System Containment Spray Subsystem Recirculation Spray Pumps and Coolers Refueling Water Chemical Addition Tank Refueling Water Storage Tank Design Basis Accident Containment Transient Analysis Amendment Nos.

TS 3.5-2 1. One residual heat removal pump may be out of service, provided immediate attention is directed to making repairs.2. One residual heat removal heat exchanger may be out of service, provided immediate attention is directed to making repairs.Basis The Residual Heat Removal System is required to bring the Reactor Coolant System from conditions of approximately 350'F and pressures between 400 and 450 psig to cold shutdown 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 one of the two pumps and/or one of the two heat exchangers is not operative, safe operation of the unit is 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 be provided with pressure interlocks to prevent them from opening when the reactor coolant system is at pressure.Management of gas voids is important to RHR System operability.

Based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations, as supplemented by system walk downs, the RHR System is not susceptible to gas intrusion, except primarily from Safety Injection Accumulator line back leakage through the RHR discharge motor operated 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 remained in local high points. Controlling RHR System operating flow rates, with the consideration to limiting inlet conditions and RCS level, prevents vortexing and air ingestion into the 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 gas accumulation or intrusion is not required.References FSAR Section 9.3 -Residual Heat Removal System Amendments Nos.

TS 4.11-3 c. 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 provided that not more than one valve has power restored at one time, and the testing and maintenance 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. The charging and low head safety injection pumps may be immobilized for this test.b. That each charging pump and safety injection pump circuit breaker actuates to its correct position upon receipt of a safety injection test signal. The charging and 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.

d. That the Safety Injection System locations susceptible to gas accumulation are sufficiently filled with water.Basis Complete system tests cannot be performed when the reactor is operating because a safety injection signal causes containment isolation.

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

Amendment Nos.

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

The test may be performed with the pumps blocked from starting.The test demonstrates the operation of the valves, pump circuit breakers, and automatic circuitry.

During reactor operation, the instrumentation which is depended on to initiate safety injection is checked periodically, and the initiating circuits are tested in accordance with Specification 4.1. In addition, the active components (pumps and valves) are to be periodically tested to check the operation of the starting circuits and to verify that the pumps are in satisfactory running order. The test interval is determined 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 of entrained gases. Preventing and managing gas intrusion and accumulation are necessary 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 review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review was supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on 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 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 Amendment Nos.

TS 4.11-4a I that the SI System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the surveillance may be declared met.Accumulated gas should 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 to radiological or environmental conditions, the plant configuration, 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 maximum potential accumulated gas void volume has been evaluated and determined to not challenge system operability.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system operability during the surveillance interval.System vent flow paths opened under administrative control are permitted to perform 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 with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.The monitoring frequency takes into consideration the gradual nature of gas accumulation 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 gas accumulation.

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 System Amendment Nos.