ML12062A069

Millstone Power Station - Response to Request for Additional Information Regarding License Amendment Request to Revise the Snubber Technical Specification Surveillance Requirements

ML12062A069
Person / Time
Site:	Millstone
Issue date:	02/24/2012
From:	Hartz L N Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME7221, 12-086
Download: ML12062A069 (5)

Text

Dominion Nuclear Connecticut, Inc.5000 Dominion Boulevard, Glen Allen, Virginia 23060 J Dom inionWeb Address: www.dom.comFebruary 24, 2012U. S. Nuclear Regulatory Commission Serial No. 12-086Attention: Document Control Desk NSSL/WDC ROWashington, DC 20555 Docket No. 50-336License No. DPR-65DOMINION NUCLEAR CONNECTICUT. INC.MILLSTONE POWER STATION UNIT 2RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDINGLICENSE AMENDMENT REQUEST TO REVISE THE SNUBBER TECHNICALSPECIFICATION SURVEILLANCE REQUIREMENTS (TAC NO. ME7221)By letter dated September 21, 2011, Dominion Nuclear Connecticut, Inc. (DNC)submitted a license amendment request (LAR) for Millstone Power Station Unit 2(MPS2) to revise Technical Specification (TS) 3/4.7.8, Snubbers. The proposedamendment would revise the TS for snubbers to conform to the revised MPS2 inserviceinspection program. In a letter dated February 9, 2012, the NRC transmitted a requestfor additional information (RAI) to DNC related to the LAR. DNC agreed to respond tothe RAI by March 7, 2012.Attachment 1 provides DNC's response to the NRC's RAI.If you have any questions regarding this submittal, please contact Wanda Craft at (804)273-4687.Sincerely,L. N. H artz ~Vice President -Nuclear Support Services

Attachment:

1. Response to Request for Additional Information Regarding License AmendmentRequest to Revise the Snubber Technical Specification SurveillanceRequirementsCommitments made in this letter:1. None4ooI Serial No. 12-086Docket No. 50-336RAI Response for Revision to TS 3/4.7.8, SnubbersPage 2 of 2cc: U.S. Nuclear Regulatory CommissionRegion I475 Allendale RoadKing of Prussia, PA 19406-1415C. J. SandersProject Manager -Millstone Power StationU.S. Nuclear Regulatory CommissionOne White Flint North11555 Rockville PikeMail Stop 08-B3Rockville, MD 20852-2738NRC Senior Resident InspectorMillstone Power Station Serial No. 12-086Docket No. 50-336RAI Response for Revision to TS 3/4.7.8, SnubbersATTACHMENT 1RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDINGLICENSE AMENDMENT REQUEST TO REVISE THE SNUBBER TECHNICALSPECIFICATION SURVEILLANCE REQUIREMENTSDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 Serial No. 12-086Docket No. 50-336RAI Response for Revision to TS 3/4.7.8, SnubbersAttachment 1, Page 1 of 2By letter dated September 21, 2011, Dominion Nuclear Connecticut, Inc. (DNC)submitted a license amendment request (LAR) for Millstone Power Station Unit 2(MPS2) to revise Technical Specification (TS) 3/4.7.8, Snubbers. The proposedamendment would revise the TS for snubbers to conform to the revised MPS2 inserviceinspection (ISI) program.- In a letter dated February 9, 2012, the NRC transmitted arequest for additional information (RAI) to DNC related to the LAR. This attachmentprovides DNC's response to the NRC's RAI.

References:

1. Dominion Nuclear, Connecticut, Inc. (Dominion), letter to NRC, "LicenseeAmendment Request (LAR) to Revise Snubber Surveillance Requirements," forMillstone Power Station, Unit 2, Docket No. 50-336, dated September 21, 2011(Agencywide Documents Access and Management System (ADAMS) AccessionNo. ML11270A051).2. Millstone Power Station Unit 2 (MPS2),. Fourth 10-Year Interval Inservice (ISI)Inspection Program and Associated Proposed Alternatives and Relief Requests,July, 2010 (ADAMS Accession No. ML102580204).3. Millstone Power Station Unit 2, Fourth 10-Year Interval Inservice InspectionProgram, August 5, 2010 (ADAMS Accession No. ML 102220527).In Reference 1, Attachment 1, Page 1 of 7, Section 3.0, "Background", the firstparagraph states that "MPS2 is currently in the fourth 10-year ISI interval. The fourth10-year interval at MPS2 began on April 1, 20,10 (References 2 and 3). Currently,snubber testing and examination are performed in accordance with the specificrequirements of Technical Specification (TS) 3/4.7.8 and the requirements contained inAmerican Society of Mechanical Engineers (ASME) Code for Operation andMaintenance of Nuclear Power Plants (OM Code), 2004 Edition." On Page 1-16,Section 1.8.25 and Page 2-34, Note 4, of References 2 and 3, it is noted that thesnubber examination and testing of snubbers is performed in accordance with the 2004Edition of the ASME OM Code, ISTD.RAI 1:Please state whether examination and testing of snubbers is performed per TS 3/4.7.8and the ASME OM Code requirements as described in Reference I or only inaccordance with ASME OM Code, ISTD requirements as noted in References 2 and 3.If MPS2 is performing examination and testing of snubbers per TS 3/4.7.8 and theASME OM Code, please explain how Dominion is meeting both sets of requirements atMPS2.

Serial No. 12-086Docket No. 50-336RAI Response for Revision to TS 3/4.7.8, SnubbersAttachment 1, Page 2 of 2DNC ResponseMPS2 is currently meeting the requirements of both TS 3/4.7.8 and ASME OM Code,ISTD, 2004 Edition (ISTD).Consistent with the guidance in NRC Regulatory Issue Summary 2010-06, "InserviceInspection and Testing Requirements of Dynamic Restraints (Snubbers)," DNCsubmitted a LAR (Reference 1) to revise the TS for snubbers to conform to therequirements of ISTD, which is MPS2's code of record for the fourth 10-year ISI interval(References 2 and 3). Consequently, until the LAR is approved by the NRC, DNC hasand will continue to meet the requirements of TS 3/4.7.8 and ISTD for examination andtesting of snubbers.During the first refueling outage in the fourth 10-year ISI interval (2R20), snubber testingwas performed to the requirements of both the TS and ISTD. Comparison of the MPS2TS and ISTD show that the snubber requirements are very similar, with somedifferences in snubber grouping and scope expansion. While the requirements of theTSs were met using existing surveillance procedures and work orders, the additionalrequirements of ISTD were addressed using newly created work orders. This willcontinue until approval of the LAR by the NRC.RAI 2:Attachment 5 of Reference 1 contains the MPS2 Snubber Program, Rev. 0, dated July21, 2011. Please indicate what snubber program was being used at MPS2 from April 1,2010 through July 21, 2011, and provide a copy of this snubber program, if it is differentthan Attachment 5.DNC ResponseFrom April 1, 2010 through July 21, 2011, the program plan for examination and testingof snubbers was delineated in the MPS2 Fourth 10-Year Interval ISI Program update(References 2 and 3). In the program update, DNC committed to the requirements ofISTD for examination and testing of snubbers. Until the TS is revised, DNC has and willcontinue to meet the requirements of both the TS and ISTD. Upon approval of the LAR,the snubber program provided in Attachment 5 of Reference 1 will be implemented.