ML18152A130

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"Draft Meeting" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.

Summary of 970708 Meeting W/Util in Rockville,Md to Discuss VEPCO Plans to Refurbish Portion of SWS at Plant.List of Attendees,Description of Refurbishment Project & Draft TS Change That Util Considering Encl
ML18152A130
Person / Time
Site: Surry  Dominion icon.png
Issue date: 08/08/1997
From: Edison G
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
NUDOCS 9708110163
Download: ML18152A130 (40)
v • d • e


Text

,-

August 8, 1997

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LICENSEE: Virginia Electric and Power Company FACILITY: Surry Power Station, Units 1 and 2

SUBJECT:

MEETING

SUMMARY

- SERVICE WATER SYSTEM REFURBISHMENT PROJECT FOR SURRY UNITS 1 AND 2 On July 8, 1997 a meeting was held at NRC headquarters in Rockville, MD to discuss Virginia Electric and Power Company's (VEPCO's) plans to refurbish a portion of the Service Water System (SWS) at the Surry Nuclear Power Station.

VEPCO provided a description of the refurbishment project (Enclosure 1), and indicated they planned to begin implementation in the fall of 1998.

A formal request for license amendment is planned to be submitted to NRC within 2 months. includes a draft technical specification change that VEPCO is considering, and two reference documents.

NRC staff indicated that any contingency plan, and any other commitments (such as project constraints) on which the NRC staff relies for its safety evaluation, will require appropriate license conditions to be added to the license.

VEPCO indicated their submittal would present the refurbishment as an unreviewed safety question because of an increase in probability (although characterized as an insignificant increase by VEPCO) of equipment malfunction due to decreased missile protection for the SWS supply line to component cooling water heat exchangers. is the meeting attendance list.

Docket Nos. 50-280 and 50-281

Enclosures:

As stated cc w/enclosures:

See next page FILENAME -

G:\\SURR.SUM

-OFFICE PM:PDII-1 LA: POii-I NAME GEdison Dunni' on DATE COPY

-- ----- ------~---

9708110163 970808 PDR ADOCK 05000280 P

PDR (Original Signed By)

Gordon Edison, Senior Project Manager Project Directorate 11-1 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation Distribution:

See next page AD:PDII-1 1111111 IIIII IIIII IIIII IIIII IIIII IIII IIII

  • &95316*

e v'irgin{a Electric and Power Company cc:

Mr. Michael W. Maupin, Esq.

Hunton and Williams Riverfront Plaza, East Tower 951 E. Byrd Street Richmond, Virginia 23219 Mr. David Christian, Manager Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883 Senior Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation P. 0. Box 1197 Richmond, Virginia 23209 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, SW, Suite 23185 Atlanta, Georgia 30303 Robert B. Strobe, M.D., M.P.H.

State Health Commissioner Office of the Commissioner Virginia Department of Health P.O. Box 2448 Richmond, Virginia 23218 e

Surry Power Station Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Mr. M. L. Bowling, Manager Nuclear Licensing & Operations Support Innsbrook Technical Center Virginia Electric and Power Company 5000 Dominion Blvd.

Glen Allen, Virginia 23060 Mr. J. P. O'Hanlon Senior Vice President - Nuclear Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060 Mr. Al Belisle U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St., SW, Suite 23185 Atlanta, Georgia 30303 Mr. W. R. Matthews, Manager North Anna Power Station P. 0. Box 402 Mineral, Virginia 23117

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Distribution

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PUBLIC PDII-1 RF OGC ACRS S. Collins/F. Miraglia R. Zimmerman B. Boger J. Tatum C. Saadu M. Tschiltz J. Johnson, RII

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1 !!ll!.!!!!111!!!~~:m~>.>.;@¥:i~~-$;~~:<::~,:~~iW.~~~~~-~l:!!11!!111!!11!111111 Project Description

Project Description lllli[!llili!l!li[llllii!j!il!l!ililliliillilillilil!!i!lllilliii!iiillliili]liil]l))Jil]Ji))JJ]!J]i!Jillili!IW.~W.:mrn~:@:::::mr=t::::::::::q::rt:::=::::::=:::t:::t:::::::::::::::t:::t::::::t:::t:::::::::::::::t:W:::t:::rnim-,\\HW~~~A~!~!![.:[l!illl))))J!§!i))!]!i))JJl!JJl!lliil]il]llllil!IJllll!iliii!iiilll]il!ll!llllil!Jiiilll!lli!IJl!-

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  • Purpose
  • Design
  • Design Basis Issues
  • Compensatory Measures
  • Contingency Plan
  • Project Constraints

Project Description

  • Purpose

>> Ongoing CW/SW Pipe Preservation Project

- clean and inspect piping, remove old coal tar epoxy coating

- weld repair pipe wall as required

- apply new 100% solids epoxy coating

>> SW supplies to RS, BC complete

>> SW supply to CCHx is next section to be addressed

- four CCHxs shared by both Units

- existing SW supply is a single 42 inch concrete-encased line

- need alternate flowpath to perform work

Project Description 811iiiil!!lilliiilill!!!liiiiili!iil!ljlillliiilllllilli!llililllilliiiiillilllilllll!iillilll!l!l!~W:(~~%1Iff?:tt:::::::t:::tf:f:ft)t:::::::t:f::::::::tf::::::,::::t'::::::::::::::::::t:tft1@:@H~ff§:~f::~"1.:~i!!!iiliii!llllll!l!lillllllll!!ii!llli!iilll!iliiil!ii!iiiiiilli!i!li!iilili!iiiiliilliiillili!illil!ll!II I I!!

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e Design

>> CC system not required for design basis ac9ident mitigating functions

- licensed as Hot Shutdown plant

>> Temporary 30 inch alternate flowpath Oumper)

- safety-related materials

-- seismically supported

-- no installed missile.protection

- manual isolation valves (three)

>> Provide SW flow to two CCHxs (A & B)

- Unit 1 Decay Heat and Spent Fuel Pit heat loads

- Unit 2 operating heat loads

A A

DISCHARGE TUNNEL I -SU-39 B

C D

I -SU-35 CONDENSER 1 *SU-31 B

C D

I -S\\l-27 102A 1028 V-1 CCHXs I -CC-E-1 A I -CC-E-1 B I -CC-E-1 C I *CC-E-1 D V-2 r----t><J--------,

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--- PIPE REPAIR

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JUMPER B

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INTAKE CANAL INLET BAYS SERVICE WATER PIPE REPAIR SURRY POWER STATION UNIT 1

Project Description lllili!i[lill[llill!!i!liJ!ili!!iiii!!iiiiillli[!!l!i!l!IIIIIIJli!!illli!lliiiiiJ!liJl!i!JIIJJJiiliiil;!~~-.~*%mrw-qti:w1:wrn~:rn::1::n:1::::=:::::@:@:{:{?'?%?:9EXE%:P:':':::@)f:I:::::::::wrnnrnm~:mw.::$M~((((!li!!!iiillll!llll!!liJl))JJiiiill!lll!ililll!!!lli!il!lllli!!lill!ll!llilil!l!illl!ilJllli!l!ll!!ll!!II ill!&

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e Design (cont.)

>> Same routing as for 1988 valve replacements

>> Other options deemed impractical

- temporary packaged cooling

- new permanent SW supply

- tie-in to another closed cooling system (BC)

>> Use for up to 35 days in each of two refueling outages

FIGURE 2 C

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Project Description e Design Basis Issues

>> Missile Protection

- original line concrete-encased

- no specific missile protection for jumper

>> Automatic Isolation SW-MOV-102A,B receive closure signal to preserve intake canal* inventory

- certain existing accident scenarios utilize manual action to effect isolation of SW to CCHx

- single m~nual inlet isolation valve provided for jumper

L Project Description 1111111111111111i111111::11111111111:11111111111111111i1111111111111111111111111111111111111rn1111111111:::.~$.'ffiW:%.%W~@:1H@:@:=::::t@t=:,:==:t:::=tt:=ttt=::=t:tt::=t:I=:@===::::=:::,:,:,:,:,:::=tm1mnrnrnmrnr~~:::::m1::::1111:1111111111111111:111111:1111111111:111111111:1111111:11:111:::111:111111:11111111:11111m11 l

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>> Utilize jumper only in late Fall, Winter, or Spring months to minimize probability of missile-producing weather

>> Approximately 76% of *routing protected to some degree by existing interve_ning structures, such as turbine deck, turbine pedestal, CCHx missile shielding

>> ~nvoke appropriate restrictions on movement of heavy loads in the vicinity of the jumper while flowing

>> Operator administrative control of inlet manual isolation valve

>> Contingency Plan for impending loss of jumper

Project Description m11m1i1i:1111111111:11111111111111111111m111n1m1111imrn1111111111111111111111111111:1111m:!111:*.w.w.rrn:~imw,rnmm,:,:,:m,m:,:,:,:,t=::ti:,t?:,t,t?::::,t=r:,:,:,:,t,:,:,:,:,:,:,:,:m::::::::=:,:,:,wm1srnimmw.m;.,w~:::M11111111111m1111111111m11111111111:111111111111111111:11111111!!111111111111111rnm11a 1,

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e Contingency Plan

>> Enter plan if certain.conditions apply

- severe weather threatens or strikes

- uncontrollable jumper leakage develops

- Unit 2 plant conditions are such that RHR is only available decay heat removal

-- loss of RCP seal injection from Charging system

Project Description e Contingency Plan (cont.)

>> Steps for implementation

- Evacuation: remove equipment, personnel, and debris from 42 inch pipe

- Restore System Integrity: install/remove pre-determined, pre-staged blanks

- Reflood: pull High Level Intake stop logs to flood up to installed SW-MOV-102 valve

-- Flow: open SW-MOV-102 valve and restore flow to C &

D CCHxs e

e

Project Description e Contingency Plan (cont.)

>> Procedure 1-AP-15.00 Loss of Component Cooling is available in the event jumper flow must be isolated prior to reflowing 42 inch pipe

>> Approximately* four hours would be needed to restore flow through the 42 inch pipe

>> Within assumed constraints, the station is expected to be able to cope for at least six hours without adverse consequences following a loss of Component Cooling

Project Description

  • Project Constraints

>> Service Water inlet temperature not greater than 80 deg F

>> Jumper safety-related material, seismically supported

>> Unit 1 core offloaded or cavity flooded while jumper flowing

>> Extreme Weather Watch (coordinate with Corporate Meterological Operations)

>> 24-hour Administrative Control of manual inlet valve

>> 24-hour Flood Watch I

>> Restrict movement of heavy loads near the jumper

>> Procedures and Training for Flood Response & Loss of CC

>> Stage emergency repair materials

>> Visual barriers around jumper

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111, Licensing Issues

Licensing Issues Hlili!!iiil!liiiliiiii!iilii!llill!liiill!i!l!!li!!iilil!lll!ll!!iiiiiiliil!i!ll!iliiiiJJl!iiJJ!!J!i!i!lli!~W,,~mrnH=;ii@Wiiifltt:titt::,m:=::ttt::,:t:t:t::t:m:,:t=:rt::::::,::::::::ttt::mm:~rnut.*rn~~~mi11111111111111111111111111111111111111111111i1111:;111m111111111111m1m11111*

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.e

  • Temporary Technical Specifications Change
  • Unreviewed Safety Question
  • Significant Hazards Consideration
  • Precedents

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  • Temporary Technical Specificat~ons Change

>> To add a footnote to TS 3.14.A.2

- To allow operation for two 35 day periods with a non-missile protected temporary SW supply line to two CCHXs

- To note that operator action will be used if isolation of non-essential SW is required

- Footnote expires after second 35 day period

>> To document NRC review of unreviewed safety question

>> To demonstrate. no significant hazards concern

Licensing Issues e Unreviewed safety question

>> Increased probability of equipment malfunction due to decreased missile protection for the SW supply line to the CCHXs

>> Insignificant increase due to compensatory measures

>> No increase in core damage frequency due to internal flooding e

el

Licensing Issues e No significant hazards consideration

>> Insignificant increase in probability of equipment malfunction

>> No new accidents are created

- Loss of Component Cooling is already addressed by the Abnormal Procedures *

- Compensatory measures maintain CDF related to flooding

>> Margin of safety is not decreased

Licensing Issues

  • a111111111111111mm11111111nHt1111111111111111111111111R11m111111111111111111j!iH!!!i!rnm~~f.~~~~~~@rn:@:Hm:ttt:::,t,:::,:,m:,:t:trftnftn::r::::::tt::r::rnm~~ti11m1~~-mmi11,11t:j11111111111111111111111111111111111111mm11111111111111111111111111111n1111111mm1111111 1

11 m111mmm11111mmm m 11.mm~rnm.1:?mw.~~~,~~.(.@'-".:o:"l;!':::m<,'$.Wlll!Wesr1111rn:111m111111emm1m; m e Precedents

>> 1988 Surry

- 30" temporary SW jumper to the CCHXs was previously used under enforcement discretion to permit SW valve replacements

  • Non-seismic
  • Allowed operation for two 72-hour periods

>> 1995 North Anna

- TS change requests submitted to allow separate 49 and 35 day allowed outage times for one SW header to the CCHXs for SW coating repairs (NAPS has two SW headers)

e

  • ~ J.J4-l 86 19 89 3.14 CIRCULATING AND SERVICE WATER SYSTEMS Applicability Applies to the operational status of the Circulating and Service Water Systems.

Objec:tive To def;ne those limiting conditions of the C1rcula"ting and Service Water Systems necessary to assure safe* station operation.

Spec:ific:ation A.

The Reactor Coolant System temperature or pressure of a reactor unit shall not exceed 3SO*F or 450 psig, respectively, or the reactor shall not be critical unless:

l.

The high level intake canal is filled to at least elevation +23.0 feet at the high level intake structure.

2.

Unit subsystems, including piping and valves, shall be operable to the extent of being able to establish the following:

a.

Flow to and from one bearing cooling water heat exchanger.

b.

Flow to and from the component co~ fleat exchangers required by Specification 3.13~

3.

At least two circu11tfng water pumps are operating or are operable.

4.

Three emergency service water pumps are operable; these pumps will service both units simult&neously.

Amendment Nos. 139 and 138 ENCLOSURE 2

e Footnote Insert for TS 3.14.A.2

  • For the purpose of performing repairs associated with the SW supply piping to the component cooling water heat exchangers (CCHXs), a temporary 30" safety-related pipe jumper will be provided to supply SW flow to and from the CCHXs required by TS 3.13. The SW piping being repaired includes the 42" service water piping from the 96" circulating water lil')es to the four SW isolation valves at the CCHXs. The basis for using the temporary jumper is provided in Virginia Electric and Power Company's letter 97-XXX dated August XX, 1997. The use of the temporary jumper is permitted two times only for a duration of up to 35 days each. If non-essential SW isolation is.

required during the pipe repair activities, it will be accomplished consistent with design basis requirements by using operator (manual) action to close the SW isolation valve in the temporary jumper within the time constraints established by the Emergency Operating Procedures. If the temporary jumper becomes inoperable during either 35 day period, the requirements of Specification 3.0.1 shall apply. Upon completion of the work associated with the second 35 day period, this footnote will no longer be applicable.

February 23, 1988 U. S. Nuclear ~e~latory C0tmnission Attention:

Document Control Desk Washington, D. C.

20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATIOB UNITS 1 AND 2 COMPONENT COOLING HEAT EXCHANGERS UTILIZATION OF TEMPORARY 30 INCH SERVICE WATER LINE Serial No.

NO/RPC:vlh Docket Nos.

License Nos.88-045.

  • RS 50-280 50-281 DPR-32 DPR-37 In preparation for the Surry Power Station Unit 1 refueling outage scheduled to begin April 2, 1988, provisions are being made to install a temporary service water flow path which will supply the Component Cooling Water Heat Exchangers while certain valves are being replaced.

This valve replacement project represents a portion of a comprehensive program of maintaining plant equipment in original design condition.

In order to avoid affecting the concurrent operation of Unit 2, an alternate 30 inch pipe must be used during two 72-hour periods to provide service water to the Component Cooling Water Heat Exchangers.

This plan of action requires that the definition of operability for the Component Cooling Water Heat Exchangers be clarified for the limited period when the temporary service water line is used.

We seek discretionary enforcement by the NRC with regard to the use of the temporary 30 inch service water line for the two 72-hour periods.

Our justification for continued operation (JCO) of Unit 2 during these periods of time is attached.

The JCO describes the systems involved, an evaluation of technical considerations, the constraint of operational limits, and compensatory measures which will be in place to respond to anticipated circumstances.

The JCO has been reviewed and approved by the Station Nuclear Safety and Operating Committee.

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

Very truly yours,

\\~u:~~

W. L. Stewart

  • Attachments

cc:

U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. w. E. Holland NRC Senior-Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager Project Directorate II-2 Division of Reactor Projects - I/II

be:

Mr. D. L. Benson - SPS Mr. H. L. Miller - SPS Mr. E. S. Grecheck - SPS E~G /*"~ GOM feiec~~ 2.-J9-SB Mr. M. L. Bowling - NAP~,;Qt}\\_-z.;.~,.

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~~~w"i~~t!SV Mr. T. B. Sowers - IN3W Mr. H. H. _!3lc!ke - IN3W

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..... go, Mr. W. D. Corbin - IN3W ~

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Ml". J. H. 8~1 el'I BJl'tF'~ 'Z./1,}MJ _;,.

Mr. G. L. Pannell - OJRPs:--Gt~/~f~S Mr. D. J. Vandewalle - OJRPS Mr. D. A. Sonmers - OJ RPS ~ z/1e./F8 Dr. T. M. Williams - RPS

~~: ~: e: ~~~~:~ : ~~~ /lie.I~ p; ?~/:p~r Mr. R. P. Cherry - OJ RPS R..fC 2-IB-88 NOD Tech Library (be original)

GOV 02-0548 Licensing Information Service E&C Records Management, NP755 - ING4 Action Plan The Design Change Package will include steps to assure the following:

1. Activities 1 and 2 shall not be perfonned during mid-nozzle operation.
2.

The fuel transfer canal will be full during Activities 1 and 2.

3.

The Reactor Coolant System configuration will be assessed prior to entry into each 72-hour valve replacement period (Activities 1 and 2).

e e

JUSTIFICATION FOR CONTINUED OPERATION SURRY POWER STATION UTILIZATIOlf OF A TEMPORARY 30 INCH SERVICE WATER LINE BACKGROUND Cast iron butterfly valves in the main condenser inlet and outlet piping and in*

the service water piping servicing the bearing cooling water, recirculation spray, and component cooling water heat exchangers have experienced degradation due to graphitic corrosion of the cast iron in a brackish water environment.

each unit and

. ~--

eight Twelve motor-operated valves will be replaced in manually-operated valves will be replaced in Unit 1.

below, will be replaced during four upcoming outages:

The valve~, ~dentified UNIT 1 REFUELING OUTAGE - Spring 1988 Condenser inlet valves CCW heat exchanger isolation valves CCW heat exchanger inlet valves UNIT 1 REFUELING OUTAGE - Fall 1989 MOV-CW-106A,B,C,D MOV-SW-102A, B l-SW-25, 29, 33, 37 Condenser outlet vaives MOV-CW-lOOA,B,C,D Bearing cooling heat exchanger isolation valves MOV-SW-lOlA,B CCW heat exchanger outlet valves l-SW-27, 31, 35, 39 UNIT 2 REFUELING OUTAGE - Fall 1988 Condenser inlet valves Service water pump suction isolation valves UNIT 2 REFUELING OUTAGE - Spring 1990 Condenser outlet valves Bearing cooling heat exchanger isolation valves MOV-CW-206A,B,C,D MOV-SW-202A, B MOV-CW-200A,B,C,D MOV-SW-201A,B The existing cast iron valves are being replaced with epoxy lined ductile iron valves.

The ductile iron is a material suitable for seismic qualification and the epoxy lining will inhibit corrosion.

1

e the upcoming

!Jiis project is one of several being actively pursued during outages to ensure the continued operability of the systems.

these valves will provide continued assurance of our ability Replacement of to isolate the service water and circulating water systems in accordance with their safety-related functions.

The MOV-SW-103's, which isolate service water to the recirculation spray heat exchangers, were replaced in a previous refueling outage.

In addition to valve replacements, repairs to the 96" circulating water piping will also be completed.

This work was begun for both units in previous outages and should be completed during the upcoming Unit 1 refueling outage.

We are currently formulating a plan to repair the balance of service water piping, but this work will proceed at a later dat.e.

. ~--

Replacement of the Unit 2 valves will be accomplished during a Unit 2 outage by providing normal system realignmant and draining.

However, since Unit 1 contains the component cooling water (CCW) heat exchangers which provide cooling to both units, a

temporary service water flow path to the CCW heat exchangers is required in order to isolate and replace the following Unit 1

valves while allowing Unit 2 to remain operational.

CCW heat exchanger isolation valves CCW heat exchanger inlet valves EVALUATION Technical Specification Requirements MOV-SW-102A,B

  • l-SW-25, 29, 33, 37 The component cooling system is an intermediate cooling system which serves both reactor units. It transfers heat from heat exchangers containing reactor coolant, other radioactive liquids, and other fluids to the service water system.

The compo~ent cooling water system has four CCW heat exchangers.

Each of the CCW heat exchangers is designed to remove the entire heat load from one unit plus one-half of the heat load common to both units during normal operation.

The capacity of one CCW heat exchanger is sufficient to remove the total heat load from Unit 2 during Unit 1 valve replacements.

Two heat exchangers are normally operated during the removal of residual and sensible*

2

  • ~

e e

heat from one unit during cooldown.

Failure of any one component of the system may extend the time required for

cooldown, but will not affect the safe operation of the station.

Abnormal procedures are in place which address a loss of component cooling water.

Technical Specification 3.13.A.l requires that for one unit operation, two component cooling water heat exchangers shall be operable. If one of these heat exchangers becomes inoperable, it must be made operable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the operating reactor shall be placed in the hot shutdown condition.

Technical Specification 3.14.A.2.B makes a

corresponding service water shall be operable to the extent of being able to requirement that establish flow to and from the component.cooling heat exchangers required by ~P-ecification 3.13.

Valve Replacement Activities Due to the existing piping configuration, replacement of valves MOV-SW-102A,B, and l-SW-25, 29, 33, and 37, requires the normal service water flow path to the CCW heat exchangers to be temporarily isolated.

Since the CCW heat exchangers must still perform a cooling function, a temporary 30 inch service water supply line will be installed to provide the cooling water.

Use of the temporary 30 inch line will be confined to two 72-hour time periods during replacement of the six service water valves. The activities to be performed during these two 72-hour periods.have been scheduled such that the work required during the clock is minimized.

Three valves will be replaced during each time period by three separate maintenance teams.

For clarification, the two time periods are referred to as Activity No. 1 and No. 2.

Valves MOV-SW-IOZB, 1-SW-25, and 1-SW-29 will be replaced during Activity No.

1.

Valves MOV-SW-102A, 1-SW-33, and l-SW-37 will be replaced during Activity No. 2 *. Activity No. 1 will be performed first. Activity No. 2 will not be initiated until at least seven days after the completion of Activity No. I.

The following work steps are accomplished in each activity:

3

e Activity No. l Replacement of MOV-SW-102B, l-SW-25, and l-SW Refer to Figure No. 1

1.

Stop logs and blank plates are installed upstream of line 96"-WC-4-10 at the high ~evel intake structure.

2.

The 30 inch temporary line is put into -service by opening temporary valves V-3, V-4, and V-5.

3.

Valves MOV-SW-102B, l-SW-25, and l-SW-29 are isolated by closing valves MOV-SW-102A, l-SW-495, l-SW-33, l-S~-35, l-SW-37, and l-SW-39 *. :~-

4.

Valves MOV-SW-102B, l-SW-25, and 1-SW-29 and their adjacent rubber expansion joints are replaced and tested.

5.

Normal service water flow to the CCW heat exchangers is reestablished by opening MOV-SW-102A and the appropriate heat exchanger isolation valves, and then closing temporary valves V-3, V-4, and V-5.

6.

Stop logs and blanks are removed as required.

NOTE:

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> JCO period starts at step 2 and ends at step 5.

The construction effort includes approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> for isolation and valve replacement and 10-15 hours for testing of the valve prior to declaring operability of the system.

The amount of time from when the old valve starts to be lifted from the srstem to the point where the new valve is lowered into place is expected to be 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

4

e Activity No. 2 Replacement of MOV-SW-102A, l-SW-33 and l-SW-37 Refer to Figure No. 1

1.

Stop logs and blank plates are installed upstream of line 96"-WC-2-10 at the high revel intake structure.

2.

CCW heat exchangers 1-CC-E-lA and 1-CC-E-IB are isolated and blank. pipe line flanges are installed downstream* of valves l-SW-33 and l-SW-37.

3.

The 30 inch temporary line is put into service by opening temporary valves V-3, V-4, and V-5

4.

Valves MOV-SW-102A, l-SW-33, and l-SW-37 are isolated by closing valves.

MOV-SW-I02B and l-SW-11, I-SW-35, and l-SW-39.

5.

Valves MOV-SW-102A, l-SW-33, and l-SW-37 and their adjacent rubber expansion joints are replaced and tested.

6.

Normal service water flow to the CCW heat exchangers is reestablished by opening MOV-SW-102B.,

l-SW-25, l-SW-29, and then closing temporary valves V-3, V-4, and V-5.

7.

Stop log and blanks are removed as required.

NOTE:

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> JCO period starts at step 3 and ends at step 6.

The construction effort includes approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> for isolation and valve replacement and 10-15 hours for testing of the valve prior to declaring operability of the system.

The amount of time from when the old valve starts to be lifted from the system to the point where the new valve is lowered into place is expected to be 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

5

'r I"

e Design Considerations of the Temporary 30" Line The 30 inch temporary service water supply line to the CCW heat exchangers has been designed with the following features:

I.

The line is fabricated and installed in accordance with Surry plant piping Specification-NUS-20 for safety-related piping and pipe class desi*gn standard STD-MEN-0004 for Class 151 pip*ing.

2.

Class 151 (150 lb carbon steel) is suitable for the design condition of 25 psig and 95°F.

Carbon steel is suitable for use with service water in this application.

Corrosion of carbon steel is not a concern since the line will be in service for short durations.

.. ~--

3. Piping materials are specified to ASTM requirements.

CMTRs are required for all pressure retaining components.

4.

The temporary line is tested prior to use in accordance with the design change package requirements.

5.

Line generally meets the "safety related" requirements of service water piping to CCW heat exchangers., except line is not seismic downstream of valve V-5 and is not missile protected.

6.

The 30 inch line up to and including valve V-5 is seismically designed and installed, thus allowing the line-to be isolated and preventing any flooding due to a seismic event.

The rationale for accepting the temporary 30 inch line as operable although nonseismic and nonmissile protected is based on the following considerations and expected plant conditions when the line is in service:

1.

The service water system is a moderate energy system, and postu;ated failure to the piping is limited to through wall cracks.

The impact of the flooding of safety-related components due to failure of the circulating water piping has been evaluated in the UFSAR and exceeds the potential flooded volume of the temporary line and is therefore bounding.

6

e

,2.

Because Unit 1 is shut down when the 30 inch temporary line is in use, the only high energy lines in the vicinity of the 30 inch temporary lines containing high energy fluid are three 3 inch steam generator blowdown lines from Unit 2, located near the CCW heat exchangers.

These lines have a minimal nunrupturing impact on the existing plant equipment and by equivalence have a minimal nonrupturing impact on the 30" line.

3.

Use of the 30 inch line will be limited to two 72-hour periods.

The*

probability of a seismic event during this period is small.

Construction Considerations The temporary 30 inch line will be utilized during two 72-hour.~:µne periods.

Construction work requiring the use of this line will be completed.::.Within this time period due to the following considerations:

I. Replacement equipment will be on hand prior to starting work.

2.

The six valves and expansion joints have flanged *ends facilitating installation and joint makeup.

3.

Flange fasteners will be replaced on a one-for-one_basis prior to replacing the valves to ensure rapid joint disassembly.

4.

The valves being replaced in each activity are physically located such that they can be worked on simultaneously.

5.

Hour by hour schedules will be used and dry run training of the valve replacements will be conducted for the construction personnel.

6 *. Valve staging will be performed to ensure the prompt replacement of the valve. If necessary to interupt the activity in order to restore component cooling, this method of replacement (staging) will facilitate prompt*

recovery.

Prompt recovery measures will be included in the general training of construction personnel.

7

.{

e Croerational Considerations The potential impact of a loss of service water to component cooling to Unit 1 in a cold shutdown condition utilizing the Residual Heat Removal system and to Unit 2 at 100%

power has been reviewed.

Use of the manual valve in the temporary 30" line to provide system isolation has also been reviewed.

The following action~ will be taken to reduce the vulnerability to a loss of component cooling event and to ensure the re9uired isolation features are provided:

1.

An operator will be assigned to the manual isolation valve, V-5, on the temporary supply line.

In the event of a pipe rupture, a

seismic event, or a design basis event, the operator will be avail~ble to close V-5 as directed by the Control Room.

2. Prior to entering the 72-hour JCO periods, the operating shifts will be briefed on the Abnormal Procedures and Emergency Operating Procedures that would be used upon loss of component cooling.

The actions would involve a reactor trip and securing the reactor coolant pumps on Unit 2 with resulting natural circulation cooling. Pressure control would be provided by alternate pressurizer spray from the charging pumps.

On Unit 1, the loss of component cooling would affect the decay heat removal capability requiring the initiation of an Abnormal Procedure.

3.

To avoid any concern about mid-nozzle operation, Activities land 2 shall not be performed during that condition.

Based on th~ above considerations and the estimated time to replace components and reestablish a cooling path if required, sufficient time would be available to initiate the necessary actions.

8

e

._~ **unreviewed Safety Question Considerations Installation of the temporary service water supply line to the component cooling heat exchangers does not constitute an "Unreviewed Safety Question" as defined in 10CFRS0.59.

Operation of the alternate service water flow path does

  • not:
1.

Increase _the probabiJ.ity of occurrence or the consequences of an accid*ent or malfunction of equipment important to safety and previously evaluated in the UFSAR.

Failure of the temporary line would cause a loss of service water to the CCW heat exchangers and would result in a loss of component cooling.

This has been evaluated in the UFSAR.

Unit 2 would be brought to.bot shutdown using existing Station Abnormal and Emergency Operating Procedures.

The probability of a loss of component cooling water is not significantly increased since the temporary line will be installed and operated in accordance with the compensatory measures identified in the JCO which establishes relative equivalence for the 30" line.

2.

Create a possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR.

The possibility for accidents or malfunctions created by these activities has been evaluated in the UFSAR. Flooding of safety-related components due to failure in the circulating water system has b*een evaluated in the UFSAR.

The flooding source which would result from a crack in the temporary line is a* bounded by the current evaluation.

For a LOCA coincident with a seismic event the temporary line will have to be isolated to conserve intake canal inventory. A manual valve will be installed in the temporary line as close as possible to the circulating water lines for isolation.

Piping between the 96 in. circulating water line and the manual valve is seismically analyzed and installed. During use of the temporary line. the intake canal -level will be maintained at a level that would maintain the required water inventory for a sufficient duration to allow for manual isolation actions before minimum allowable level is reached.

9

e

3.

Reduce the margin of safety as defined in the basis for any Technical Specification.

The temporary line will be used only for short periods of time when Unit I is in cold shutdown.

Operation of the temporary line under the conditions imposed will ~rovide sufficient service water flow to meet the design basis requirements for single unit operation. A break in this temporary line would not reduce the flow to the recirculation spray heat.exchangers during an accident condition. Administrative controls will be provided to close the isolation valve to the temporary line if required.

Construction of the temporary line will be accomplished in accQrdance with applicable station procedures to ensure that plant safety is maintained.

CONCLUSION Due to the corrosion, the service water butterfly v~lves*require replacement.

During certain valve replacements, the normal service water supply to the CCW heat exchangers must be isolated and drained.

In order to keep the CCW heat exchangers functional, a temporary 30 inch service water supply line will be utilized.

This line is used during two 72-hour ~ime periods which is consistent with the standard service water system technical specification LCO time periods as detailed in the Standard Technical Specifications for Westinghouse Pressurized Water Reactors (NUREG-0452).

The 30 inch line is designed to provide full flow to one CCW heat exchanger, is constructed with safety-related material, is hydrostatically tested prior to use and is seismic up through the first isolation valve.

Use of this line will provide the cooling water necessary for Unit 2 to remain operational.

In the event the line requires isolation and is nonfunctional, Unit 2 can be brought to hot shutdown using existing station procedures.

This evaluation has shown that the intent of the relevant technical specifications has been met by providing an alternate flow path with design and operational considerations provided for a non-missile protected and non-seismic line. Therefore, these measures provide the justification for continued operation of Unit 2 using the temporary service water supply to the CCW heat exchangers.

10

Figure 1

  • suRRY U,V/TS 1 AND 2 CJRC. AND SERVICE ~4TER VALVE REPLACEMENTS I

IDENTIFIC4TION OF UNIT J i*~4LVES A

  • ID

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C)

NNIH L1V1L lffAICI

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C) l'1.0W ~A'TM*

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-- ~-------------------------~

C

  • NUCLEAR REGULATORY COMMISSION e

REGION II 101 MARIETTA STREET, N.W.

ATLANTA, GEORGIA 30323 MAR 3 O 1~88 Virginia Electric and Power CompParneys,*dent, i"'i--_*~--

ATTN:

Mr.-*W--:-*-*l:.-:--5tl!Wart, Vice v

Nuclear Operations P. 0. Box 26666 Richmond, VA 23261 Gentlemen:

e Serial 1-_3...,._,g..__-:-___./ ___ 7_7 ___

Rec'd. APR 5 1988 Nuclear Operations

~ensing Supervisor.~

SUBJECT:

ENFORCEMENT DISCRETION FOR SURRY POWER STATION UNITS 1* AND 2 DOCKET NOS. 50-280 AND 50-281 This letter acknowledges your letter (serial no.88-045) of February 23, 1988, r.equesting relief from the operability requirements of Technical Specifications (TS) 3.13 and 3.14 during a planned service water valve replacement.

In a telephone conversation on March 22, 1988, you were informed that dis~retionary enforcement action would be granted for two 72-hour periods to permit continued operation of Unit 2 while nuclear service water valve repairs proceea. ** During these two 72-hour periods, a temporary non-seismically qualified 30-inch diameter service water line will be used* to provide cooling water to the Component Cooling Water Heat Exchangers.

It is our understanding that the operational considerations indicated in your letter will be in effect during the valve replacement.

Further, although not specifically stated but tacitly implied in your letter, we will require that should the time limitation (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) imposed on the replacement evolutions be exceeded, the service water flow path and component cooling water heat exchangers shall be restored to fully operable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or Unit 2 shall be placed in the hot shutdown condition.

cc:

D. L. Benson, Station Manager N. E. Hardwick, Manager - Nuclear Programs and Licensing Sincerely, J. Nelson Grace Regional Administrator

'I "'J' iw,.- L.,

I("~ I*

,._}

Name Gordon Edison Jim Tatum John Waddill Addison Hall Gary D. Miller Barry C. Bryant David A. Sommers Ashok V. Barkley Coretta Y. Saadu Attendance at Meeting Held July 8, 1997 with NRC and VEPCO Orqani zation NRC NRC ENCLOSURE 3 VA Power - Engineering VA Power - Engineering VA Power - Licensing VA Power - Licensing VA Power - Licensing VA Power - Project Engineer NRC

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