ML081980640

/3, North Anna Power, Units 1/2, & Surry Power Station, Units 1/2, Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling (TAC Nos. MD7838, MD7845, MD7846, MD7850, MD7851, MD7884, & MD7885)

ML081980640
Person / Time
Site:	Millstone, Kewaunee, Surry, North Anna
Issue date:	07/23/2008
From:	Melanie Wong NRC/NRR/ADRO/DORL/LPLII-1
To:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
Lingam, Siva NRR/DORL 415-1564
References
GL-08-001, TAC MD7838, TAC MD7845, TAC MD7846, TAC MD7850, TAC MD7851, TAC MD7884, TAC MD7885
Download: ML081980640 (8)

Text

July 23, 2003 Mr. Gerald T. Bischof Vice President Nuclear Engineering Virginia Electric and Power Company Dominion Nuclear Connecticut, Inc.

Dominion Energy Kewaunee, Inc.

Glen Allen, Virginia 23060

SUBJECT:

KEWAUNEE POWER STATION, MILLSTONE POWER STATION, UNITS 2 AND 3, NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, AND SURRY POWER STATION, UNIT NOS. 1 AND 2 - GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, RESPONSE TO EXTENSION REQUEST (TAC NOS. MD7838, MD7845, MD7846, MD7850, MD7851, MD7884 AND MD7885)

Dear Mr. Bischof:

On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

By letter dated May 8, 2008, Dominion Energy Kewaunee, Inc., Dominion Nuclear Connecticut, Inc., and Virginia Electric and Power Company (the licensees), submitted a 3-month response to GL 2008-01 for Kewaunee Power Station (Kewaunee), Millstone Power Station, Units 2 and 3 (Millstone 2 and 3), North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2), and Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2), and proposed alternative actions to the 9-month response date of October 11, 2008, for Millstone 3, North Anna 1 and 2, and Surry 1. The NRC staffs assessment of the response for Millstone 3, North Anna 1 and 2, and Surry 1 is contained in the Enclosure.

The NRC staff reviewed the licensees proposed alternative course of action and concluded that for Millstone 3, North Anna 1 and 2, and Surry 1, with the exception of the clarifications and associated requests discussed in the Enclosure, it is acceptable. This letter allows the licensee to

implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the Enclosure.

This letter does not alter or change the requested 9-month response date of October 11, 2008, for Kewaunee, Millstone 2 and Surry 2.

If you have any questions regarding this issue, please contact Siva P. Lingam, your assigned Project Manager, at 301-415-1564 or, via email, at Siva.Lingam@nrc.gov.

Sincerely,

/RA/

Melanie C. Wong, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-305, 50-336, 50-423, 50-338, 50-339, 50-280 and 50-281

Enclosure:

Assessment of 3-month response cc w/encl: See next page

ML081980640 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/DSS/PGCB/BC NRR/DSS/DD NRR/LPL2-1/BC NAME SLingam MOBrien MMurphy JWermiel MWong DATE 07 / 21 /08 07 / 21 /08 07 / 23 /08 07 / 23 /08 07 / 23 /08

Kewaunee Power Station, Millstone Power Station, Units 2 and 3, North Anna Power Station, Unit Nos. 1 and 2, and Surry Power Station, Unit Nos. 1 & 2 cc:

Mr. David A. Christian President and Chief Nuclear Officer Virginia Electrical and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Ms. Lillian M. Cuoco, Esq.

Senior Counsel Dominion Resources Services, Inc.

120 Tredegar Street, RS-2 Richmond, VA 23219 Mr. Donald E. Jernigan Site Vice President Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883-0315 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 Post Office Box 1197 Richmond, Virginia 23218 Dr. Robert B. Stroube, MD, MPH State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc.

Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711 Mr. C. Lee Lintecum County Administrator Louisa County Post Office Box 160 Louisa, Virginia 23093 Old Dominion Electric Cooperative 4201 Dominion Blvd.

Glen Allen, Virginia 23060 Senior Resident Inspector North Anna Power Station U. S. Nuclear Regulatory Commission P. O. Box 490 Mineral, Virginia 23117 Mr. Daniel G. Stoddard Site Vice President North Anna Power Station Virginia Electric and Power Company Post Office Box 402 Mineral, Virginia 23117-0402 Mr. William R. Matthews Senior Vice President, Nuclear Operations Virginia Electrical and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Kewaunee Power Station, Millstone Power Station, Units 2 and 3, North Anna Power Station, Unit Nos. 1 and 2, and Surry Power Station, Unit Nos. 1 & 2 cc:

Edward L. Wilds, Jr., Ph.D.

Director, Division of Radiation Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 First Selectmen Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Charles Brinkman, Director Washington Operations Nuclear Services Westinghouse Electric Company 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852 Senior Resident Inspector Millstone Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 Mr. J. W. "Bill" Sheehan Co-Chair NEAC 19 Laurel Crest Drive Waterford, CT 06385 Ms. Nancy Burton 147 Cross Highway Redding Ridge, CT 00870 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terrys Plain Road Simsbury, CT 06070 Mr. Joseph Roy Director of Operations Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056 Mr. William D. Bartron Licensing Supervisor Dominion Nuclear Connecticut, Inc.

Building 475, 5th Floor Roper Ferry Road Waterford, CT 06385 Mr. J. Alan Price Site Vice President Dominion Nuclear Connecticut, Inc.

Building 475, 5th Floor Rope Ferry Road Waterford, CT 06385 Ms. Leslie N. Hartz Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N 490 Highway 42 Kewaunee, WI 54216 Resident Inspectors Office U. S. Nuclear Regulatory Commission N490 Highway 42 Kewaunee, WI 54216-9510 Mr. Thomas L. Breene Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216

Enclosure ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 KEWAUNEE POWER STATION, MILLSTONE POWER STATION, UNITS 2 AND 3, NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, AND SURRY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-305, 50-336, 50-423, 50-338, 50-339, 50-280, AND 50-281 1.0 Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2.0 Licensees Proposed Alternative Course of Action By letter dated May 8, 2008 (ADAMS Accession No. ML081300282), Dominion Energy Kewaunee, Inc., Dominion Nuclear Connecticut, Inc., and Virginia Electric and Power Company (the licensees), submitted a 3-month response to GL 2008-01 for Kewaunee Power Station (Kewaunee), Millstone Power Station, Units 2 and 3 (Millstone 2 and 3), North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2), and Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2), and proposed alternative actions to the 9-month response date of October 11, 2008, for Millstone 3, North Anna 1 and 2, and Surry 1. The licensees indicate that they will provide a 9-month response to GL 2008-01, consistent with the GLs requested schedule by October 11, 2008, that will address the required aspects of the GL for Millstone 3, North Anna 1 and 2, and Surry 1. This letter does not alter or change the requested 9-month response date of October 11, 2008, for Kewaunee, Millstone 2 and Surry 2. However, the licensees request additional time after completion of the confirmatory walkdown in the following scheduled refueling outages to submit supplemental response for Millstone 3, North Anna 1 and 2, and Surry 1:

Millstone 3 fall 2008 North Anna 2 fall 2008 North Anna 1 spring 2009 Surry 1 spring 2009 As an alternative course of action, the licensees provide the following commitments for completion of the GL response for Millstone 3, North Anna 1 and 2, and Surry 1:

1.

Provide a supplemental response to GL 2008-01 by January 15, 2009, for Millstone 3 and North Anna 2.

2.

Provide a supplemental response to GL 2008-01 by July 15, 2009, for North Anna 1 and Surry 1.

3.0 NRC staff Assessment The NRC staff finds that for Millstone 3, North Anna 1 and 2, and Surry 1, with the exception of the clarifications and associated requests discussed below, the licensees proposed alternative course of action is acceptable.

The NRC staff notes that the licensees May 8, 2008, response does not clearly describe the content to be provided in its 9-month submittals. The NRC staff requests that the licensee submit the information requested in the GL as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the refueling outages in accordance with the schedule listed in Section 2.0 of this evaluation for Millstone 3, North Anna 1 and 2, and Surry 1, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC by January 15, 2009, for Millstone 3 and North Anna 2, and July 15, 2009, for North Anna 1 and Surry 1.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated May 8, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suction piping, as well as, whether analysis development is needed to assess gas transport in the subject system piping as a function of system flow. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensees address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensees responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

Date: July 23, 2008