ML022130519
| ML022130519 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 07/26/2002 |
| From: | Hartz L Virginia Electric & Power Co (VEPCO) |
| To: | NRC/Document Processing Center |
| References | |
| 02-360A, LR/DEA: R0 | |
| Download: ML022130519 (10) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 28261 July 26, 2002 United States Nuclear Regulatory Commission Serial No.:
02-360A Attention: Document Control Desk LR/DEA:
RO Washington, DC 20555-0001 Docket Nos.:
50-280/281 50-338/339 License Nos.: DPR-32/37 NPF-4/7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY AND NORTH ANNA POWER STATIONS UNITS I AND 2 LICENSE RENEWAL - COMMENTS ON DRAFT SER In a letter dated June 6, 2002, the NRC provided Virginia Electric and Power Company (Dominion) the draft Safety Evaluation Report (SER) for license renewal of North Anna Power Station, Units 1 and 2, and Surry Power Station, Units 1 and 2. The draft SER was provided for comment and response to the open items and confirmatory actions.
The NRC staff identified eight open items and fifteen confirmatory actions associated that require resolution. Dominion provided the requested response to the open items and a disposition of the confirmatory actions identified in the draft SER in a letter dated July 25, 2002 (Serial No.02-360).
As requested, the draft SER has been reviewed for accuracy and consistency against the License Renewal Applications submitted for Surry and North Anna Power Stations and subsequent information provided by Request for Additional Information responses.
Dominion's comments are attached.
In the transmittal letter with the draft SER, the NRC staff described their plans to review the format of the SER to further improve the content while incorporating comments and responses.
Accordingly, Dominion's comments are limited to items that might be considered to have implications on the bases of the conclusions presented in the SER if not resolved for consistency with the License Renewal Application.
Should you have any questions regarding this submittal, please contact Mr. J. E.
Wroniewicz at (804) 273-2186.
Very truly yours, Leslie N. Hartz Vice President - Nuclear Engineering Attachment Commitments made in this letter: None
Serial No.: 02-360A SPS/NAPS LR - Comments on Draft SER cc page 1 of 4 cc:
U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, GA 30303-8931 Mr. M. J. Morgan NRC Senior Resident Inspector North Anna Power Station Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station Mr. J. E. Reasor, Jr.
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
Suite 300 Glen Allen, VA 23060 Ms. Ellie Irons, EIR Program Manager Virginia Dept. of Environmental Quality 629 East Main St., 6 th FI Richmond, VA 23219 Mr. David Paylor, Program Coordinator Virginia Dept. of Environmental Quality P.O. Box 10009 Richmond, VA 23240-0009 Mr. Joe Hassell, Environmental Manager Virginia Dept. of Environmental Quality Water Division P.O. Box 10009 Richmond, VA 23240-0009
Serial No.: 02-360A SPS/NAPS LR - Comments on Draft SER cc page 2 of 4 Mr. Frank Daniel, Regional Director Virginia Dept. of Environmental Quality Tidewater Regional Office 5636 Southern Blvd.
Virginia Beach, VA 23462 Mr. Gregory Clayton, Regional Director Virginia Dept. of Environmental Quality Northern Virginia Regional Office 13901 Crown Ct.
Woodbridge, VA 22193 Mr. Frank Fulgham, Program Manager Virginia Dept. of Agriculture & Consumer Services Office of Plant & Pest Services 1100 Bank St.
Richmond, VA 23219 Mr. David Brickley, Agency Director Virginia Dept. of Conservation & Recreation 203 Governor St.
Richmond, VA 23219 Mr. William Woodfin, Director Virginia Dept. of Game & Inland Fisheries 4010 West Broad St.
Richmond, VA 23230 Mr. Robert Hicks, Director Virginia Dept. of Health Office of Environmental Health Services 1500 East Main St., Room 115 Richmond, VA 23219 Ms. Kathleen S. Kilpatrick, Director Virginia Dept. of Historic Resources State Historic Preservation Office 2801 Kensington Ave.
Richmond, VA 23221
Serial No.: 02-360A SPS/NAPS LR - Comments on Draft SER cc page 3 of 4 Dr. Ethel Eaton, Archeologist Senior Virginia Dept. of Historic Resources State Historic Preservation Office 2801 Kensington Ave.
Richmond, VA 23221 Mr. Robert W. Grabb, Assistant Commissioner Virginia Marine Resources Commission 2600 Washington Ave.
Newport News, VA 23607 Dr. John Olney, Associate Professor Virginia Institute of Marine Science School of Marine Science Gloucester Point, VA 23062 Mr. John Simkins Virginia Dept. of Transportation Environmental Division 1401 East Broad St.
Richmond, VA 23219 Mr. Robert Burnley Virginia Economic Development Partnership 901 East Byrd St.
Richmond, VA 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Energy Regulation 1300 East Main St., 4 Fl., Tyler Bldg.
Richmond, VA 23219 Mr. Michael Cline, State Coordinator Commonwealth of Virginia Department of Emergency Management 10501 Trade Rd.
Richmond, VA 23236-3713 Mr. Terry Lewis, County Administrator P.O. Box 65 Surry, VA 23883
Serial No.: 02-360A SPS/NAPS LR - Comments on Draft SER cc page 4 of 4 Mr. Lee Lintecum Louisa County Administrator P.O. Box 160 Louisa, VA 23093 Mr. Douglas C. Walker Acting Spotsylvania County Administrator P.O. Box 99 Spotsylvania, VA 22553 Ms. Brenda G. Bailey, County Administrator P.O. Box 11 Orange, VA 22960 Chairman Reeva Tilley Virginia Council on Indians P.O. Box 1475 Richmond, VA 23218 Mr. Don Lillywhite, Director Economics Information Services Virginia Employment Commission State Data Center 703 East Main St., Room 213 Richmond, VA 23219 Mr. Alan Zoellner Government Information Department Swem Library College of William and Mary Landrum Dr.
P.O. Box 8794 Williamsburg, VA 23187-8794 Mr. Walter Newsome Government Information Resources Alderman Library University of Virginia 160 McCormick Rd.
P.O. Box 400154 Charlottesville, VA 22904-4154
Docket Nos. 50-280/281 50-38/339 Serial No.: 02-360A Attachment Page 1 of 5 Attachment License Renewal - Comments on Draft SER Serial No. 02-360A Comments on Draft Safety Evaluation Report Dated June 6, 2002 Surry and North Anna Power Station, Units 1 and 2 License Renewal Virginia Electric and Power Company (Dominion)
Docket Nos. 50-280/281 50-38/339 Serial No.: 02-360A Attachment Page 2 of 5 Comments on Draft SER for Surry and North Anna Power Station License Renewal Applications Comment #1:
General comment.
Various sections and pages Request for Additional Information (RAI) 2.1-3 caused Dominion to re-assess the license renewal scope for components and systems with regard to 10CFR54.4(a)(2). As a result, additional systems, or portions of systems, were added to the scope of license renewal for each station because of their spatial orientation in and around safety related systems. The draft SER (Section 3) does not accurately reflect the inclusion of these systems in the Aging Management Review Results. It is recommended that the NRC staff consider addressing these systems in a global manner by inclusion of a specific discussion in Section 2.3, Scoping and Screening Results: Mechanical Systems.
Comment #2:
Section 2.1.3.1 Page 2-10 3rd paragraph, next to last sentence:
Delete this sentence beginning with "The SDBD..." in its entirety.
The System Design Basis Documents (SDBDs) have a controlling procedure but they do not fall under the cognizance of the Nuclear Quality Assurance Program. The referenced LR guideline (LRPG 501) provides the requirements for preparing, reviewing, and approving License Renewal technical reports, but does not control any part of the process to develop or maintain the SDBDs.
Docket Nos. 50-280/281 50-38/339 Serial No.: 02-360A Attachment Page 3 of 5 Comment #3:
Section 2.1.3.2 Page 2-17 Electrical Components, 2 nd 3P, and 4 th sentences:
This paragraph needs to be revised to clarify that those electrical/l&C components, that are included in the license renewal scope only because they performed a pressure boundary function, were treated as mechanical components in the system screening process.
The remaining electrical/l&C components were categorized into component groups regardless of whether or not they had mark numbers.
Therefore, delete the 2nd and 3 rd sentences and replace them with the following:
"The electrical/l&C components that are in scope because they perform a pressure boundary function are shown on system drawings. The applicant has treated these electrical/I&C components as mechanical components and identified them during system screening."
At the beginning of the 4th sentence replace "For the non-mark numbered components" with "For the remaining electrical/I&C components."
Comment #4:
Section 2.4.1 Page 2-165 1st paragraph, 3 rd sentence:
The statement "The NAS UFSAR does not address the containment structure for the North Anna plant." is not correct. It should be replaced with the following statement: "The design of the NAS 1/2 containment structures is described in NAS UFSAR Sections 3.7 and 3.8.2."
Docket Nos. 50-280/281 50-38/339 Serial No.: 02-360A Attachment Page 4 of 5 Comment #5:
Section 3.4.3.1.1 Page 3-127 4th paragraph, starting with 3rd sentence:
The information in the following sentences is not correct as stated.
"For the individual subcomponents, the design loadings fit into the normal, upset, or faulted conditions as defined in the ASME Boiler and Pressure Vessel Code,Section III. The allowable stress limits during the design basis accident (DBA) used for the core support structures are based on the January 1971 draft of the ASME Code for Core Support Structures, Subsection NG, and the Criteria for Faulted Conditions."
To be consistent with SER Section 4.3.2, page 4-13, this paragraph should be revised to state: "The SPS and NAS reactor internals were designed to Westinghouse criteria, which were established prior to the issuance of the ASME Code Section III Subsection NG. The Westinghouse criteria contained no TLAAs and used pressure load calculations instead of fatigue calculations."
The Westinghouse design of the reactor vessel internals is similar for both the three-loop plants designed with the Westinghouse criteria and the three-loop plants designed with ASME Section III Subsection NG criteria. In addition, the design transients for the reactor coolant system (RCS), including the reactor vessel internals, are similar.
Docket Nos. 50-280/281 50-38/339 Serial No.: 02-360A Attachment Page 5 of 5 Comment #6:
Section 3.4.3.1.2 Page 3-128 3rd paragraph, last sentence:
The statement that the applicant identifies "Metal Fatigue" as an applicable TLAA associated with the RV internals is incorrect. The sentence should either be deleted or replaced with the statement "In addition, the applicant does not identify any TLAAs associated with the RV internals."