IR 05000395/2022010

NRC Inspection Report 05000395 2022010

ML22069B079
Person / Time
Site:	Summer
Issue date:	03/10/2022
From:	Binoy Desai Division of Reactor Safety II
To:	Stoddard D Dominion Energy Co
References
IR 2022010
Download: ML22069B079 (13)

Text

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION - NRC INSPECTION REPORT 05000395/2022010

Dear Mr. Stoddard:

On February 18, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a post approval site inspection for license renewal at Virgil C. Summer Nuclear Station and discussed the results of this inspection with Mr. Robert Justice, Plant Manager and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Binoy B. Desai, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 05000395 License Nos. NPF-12

Enclosure:

As stated

Inspection Report

Docket Number: 05000395

License Number: NPF-12

Report Number: 05000395/2022010

Licensee: Dominion Energy

Facility: Virgil C. Summer Nuclear Station

Location: Jenkinsville, SC

Inspection Dates: January 31, 2022 to February 18, 2022

Inspectors: S. Downey, Senior Reactor Inspector (Lead)

I. Anchondo-Lopez, Materials Engineer P. Cooper, Senior Reactor Inspector M. Magyar, Reactor Inspector M. Schwieg, Senior Reactor Inspector

Approved By: Binoy B. Desai, Chief Engineering Branch 3 Division of Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Post-Approval Site Inspection for License Renewal at Virgil C.

Summer Nuclear Station, in accordance with the license renewal inspection program (LRIP). The LRIP is the process used by the NRC staff to verify the adequacy of aging management programs (AMPs) and other activities associated with an applicants request to renew an operating license of a commercial nuclear power plant beyond the initial licensing period under Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

71003 - Post-Approval Site Inspection for License Renewal

From January 31st to February 18th, the NRC continued monitoring Dominions performance at Virgil C. Summer Nuclear Station by conducting a Post-Approval Site Inspection for License Renewal - Phase II in accordance with the license renewal inspection program (LRIP). This inspection took place prior to the period of extended operation (PEO)for Unit 1, which will begin on August 6, 2022. Per IMC 2516, the LRIP is the process used by NRC staff to verify the adequacy of aging management programs (AMPs), Time Limited Aging Analyses (TLAAs), and other activities associated with an applicants request to renew an operating license of a commercial nuclear power plant beyond the initial licensing period under 10 CFR Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants.

(1) License Conditions and Commitments for License Renewal, Implementation of Aging Management Programs and Time-Limited Aging Analyses

There are a total of 41 regulatory commitments linked to the renewed operating license for Virgil C Summer Nuclear Station, Unit 1, issued in April 2004, which include the following: 7 standalone commitments (not associated with an AMP or TLAA); 17 commitments to implement new aging management programs;, 9 commitments to enhance existing aging management programs for license renewal, 2 commitments to perform a one-time inspections of SSCs within the scope of an existing AMP, and 6 commitments to perform Time Limited Aging Analyses. During the inspection, the team reviewed a majority sample (greater than 70%) of regulatory commitments and associated AMPs and TLAAs in order to assess the adequacy and effectiveness of the license renewal program. For each item selected in the sample, the inspectors also reviewed the applicable license renewal program documents, conducted interviews with licensee staff, and performed system walkdowns as needed to verify that the licensee completed the actions necessary to comply with the conditions listed in the renewed facility operating license. For those license renewal action items that were not completed at the time of this inspection, the team verified that there was reasonable assurance that such action items were on track for completion prior to the PEO or in accordance with an established implementation schedule consistent with the license renewal application (LRA), the NRC safety evaluation report (SER), and the Updated Final Safety Analysis Report (UFSAR) supplement.

The regulatory commitments selected for the inspection sample are listed below along with the completion status of the item at the time of the inspection. The full description of each commitment is available in the UFSAR supplement for license renewal, as revised, and Appendix A of the NRC SER issued as NUREG-1787.

Commitment #1:Updates to FSAR to address the applicability of the Quality Assurance Program. Status: Complete.

Commitment #2:Above Ground Tank Inspection. Status: Complete.

Commitment #3: Enhancement of the Alloy 600 Aging Management Program to incorporate applicable emerging regulatory requirements and efforts developed by industry groups applicable to different attributes to the program. Status: Complete.

Commitment #4: Enhancement to the Boric Acid Corrosion Surveillance for those systems outside of containment. Status: Complete.

Commitment #5: Enhancement to the Underground Piping and Tank Integrity Program to perform inspections to verify and manage the loss of material on the external surfaces of buried components. Status: Complete.

Commitment #6: Enhancement to the Chemistry Program to perform one-time inspections of low flow areas of various treated water systems. Status: Complete.

Commitment #7: One-time inspection for the Diesel Generator System. Status:

Complete

Commitment #8: Enhancement to the Fire Protection Program to replace, or test, sprinklers in accordance with NFPA 25. Status: Not Complete. The licensee received NRC approval (ADAMS Accession No. ML21203A021) to extend the deadline to complete the actions associated with Commitment #8 from August 6, 2022, to April 2029. The inspectors noted that the basis for the commitment change was to align with the requirements of NFPA 25 to test or replace sprinklers that have been in place for 50 years. Based on the review of the administrative controls in place to track the pending actions, the inspectors determined that there was reasonable assurance that the licensee would complete the necessary actions to meet Commitment #8. Therefore, no follow-up inspection is warranted.

Commitment #9: Enhancement to the Fire Protection Program to perform ultrasonic testing of stagnant sections of fire protection piping. Status: Complete.

Commitment #10:One-time inspection of brass and cast-iron components in the Fire Service System. Status: Not Complete. Specifically, laboratory analysis to detect and classify loss of material in 8 of 8 brass hose reel isolation valves, 5 of 7 cast iron underground fire main post indicator isolation gate valves (PIVs), and 2 of 4 cast iron fire hydrant valves, has been completed. At the time of the inspection, the remaining cast-iron PIVs (XVG04007-FS, XVG04008-FS) and fire hydrant valves (XFX0001N, XFX0001A) had not been sent to the laboratory. Based on the review of the administrative controls in place to track the pending actions, the inspectors determined that there was reasonable assurance that the licensee would complete the necessary actions to meet Commitment #10. Therefore, no follow-up inspection is warranted.

Commitment #11: Implementation of the Non-EQ Cables and Connections Inspection Program. Status: Complete.

Commitment #12: Enhancement to the In-service Inspection Plan to maintain active participation in industry groups and review pertinent developments associated with the aging management of the Core Support Pads and Bottom Head Penetrations. Status:

Complete.

Commitment #13: Inspection of Mechanical Components. Status: Complete.

Commitment #14: One-time inspection of the Liquid Waste System for assessing the aging management of applicable stainless-steel pipes, valves, and heat exchanger.

Commitment #15: Enhancement to the Maintenance Rule Structures Program. Status:

Complete

Commitment #16: One-time inspection for Reactor Building Cooling System. Status:

Complete.

Commitments 17 & 18: Implementation of the Reactor Vessel Internals Inspection.

Status: Complete

Commitment #19: Enhancement to the Reactor Vessel Surveillance Program to verify that materials in the nozzles and upper shell course will not become controlling during the PEO. Status: Complete.

Commitment #20: Enhancement to the Reactor Vessel Surveillance Program to revise the capsule withdrawal schedule and to use alternative dosimetry. Status: Complete

Commitment #21: One-time inspection for Service Air System. Status: Complete.

Commitment #22: Enhancements to the Service Water Dam Inspection Program. Status:

Complete

Commitment #23: One-time inspection of small-bore Class 1 stainless steel piping and fittings less than four inches nominal pipe thickness. Status: Complete.

Commitment #24: One-time inspection for Waste Gas System. Status: Complete

Commitment #25: Heat Exchanger Inspections. Status: Complete

Commitment #26: Implementation of the Area Based Inspections for Refined 10 CFR 54.4(a)(2) Criteria Commodities Program. Status: Complete

Commitment #27: Implementation of the Aging Management Program for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. Status: Complete

Commitment #28: Implementation of the License Renewal Aging Management Program for Non-EQ Electric Cables and Connections Used in Instrumentation Circuits. Status:

Complete.

Commitment #29: Implementation of the Aging Management Program for Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. Status: Complete.

Commitment #36: Enhancement to Station Programs to include reference to License Renewal. Status: Complete

Commitment #38: Establish process to meet the requirements of 10 CFR 54.35. Status:

Complete

Commitment #39: Plant procedures which impact "control of facility changes", including modifications and documentation, to verify an acceptable screening review process against the 10 CFR 54 requirements to ensure consistency with the LRA methodology and guidance. Status: Complete.

Commitment #40: Establish LRA Methodology and Guidance Program. Status:

Complete

Commitment #41: All Technical Reports developed to substantiate the LRA are filed as permanent records. Status: Complete.

(2) Newly Identified Structures, Systems, and Components

Since the renewed license was issued, the licensee has performed three assessments to identify any SSCs that would have been subject to an aging management review or evaluation as a time-limited aging analysis in accordance with 10 CFR 54.21. At the time of the inspection, the following assessments were available for review:

Engineering Documents for License Renewal/Aging Management Program Impact 54.37(b) Review 2004-2020 V.C. Summer Plant Life Extension NFPA 805 Impact Review

The inspectors reviewed the licensees assessments and noted that the following SSCs were identified as being within the scope of license renewal and subject to aging management review.

Diesel Generator Jack Water Head Tanks Boron Recycle Hold Up Tanks Portions of the Chemical and Volume Control System Portions of the Control Building Wet Pipe Sprinkler System Portions of the Emergency Feedwater System

For each newly identified SSC, the inspectors determined that the licensee took appropriate actions in accordance with 10 CFR 54.37(b). Specifically, the inspectors verified that, when necessary, the SSCs have been included in the FSAR update required by 10 CFR 50.71(e),and that the FSAR update describes how the effects of aging are managed. The inspectors also reviewed a list of plant modifications performed from the time the LRA was submitted to the time the renewed operating license was issued, to identify any potentially new SSCs that would have been subject to aging management review at the time the NRC was reviewing the LRA. Based on this review, the inspectors did not identify any new SSCs that were subject to the provisions of 10 CFR 54.37(b).

(3) Description of Aging Management Programs in the UFSAR Supplement

As part of the review of implementation activities for the selected AMPs, the team reviewed the corresponding UFSAR sections to verify that the program descriptions were consistent with the license renewal application and the corresponding section of the NRC safety evaluation report. The team reviewed three versions of the UFSAR supplement for license renewal as follows:

The team reviewed the UFSAR supplement submitted with the LRA, as revised, to identify the program attributes and future inspection activities that were originally relied upon for the approval of the renewed operating license.

The team reviewed the revision of the UFSAR submitted to the NRC pursuant to the requirements in 10 CFR 50.71(e)(4) following the issuance of the renewed operating license to verify that the UFSAR supplement for license renewal was included with the UFSAR as required by the condition of the renewed operating license.

The team reviewed the latest revision of the UFSAR supplement for license renewal to verify that the program attributes and inspection activities were consistent with the AMPs as originally approved by the NRC and subsequent revisions performed under the provisions of 10 CFR 50.59. The team also verified that any changes caused by the inclusion of newly identified SSCs were included in the UFSAR supplement.

(4) Changes to license renewalcommitments and the UFSAR supplement for license renewal

As part of the review of license renewal commitments, AMPs, and TLAAs describedin thisreport, the inspectors reviewed license renewal commitment change documents to verify the licensee followed the guidance in NEI 99-04, Guidelines for Managing NRC Commitment Changes, for any change to the commitments, including their elimination. The team verified that the licensee properly evaluated, reported, and approved where necessary, changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59.

The team also reviewed the licensees procedures for commitment revision to obtain reasonable assurance that future changes to regulatory commitments would follow the guidance in NEI 99-04, and would properly evaluate, report, and approve changes to license renewal commitments listed in the UFSAR.

INSPECTION RESULTS

No findings or violations identified

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On February 17, 2022, the inspectors presented the NRC inspection results to Mr.

Robert Justice and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71003 Calculations DC04030-003 Reactor Vessel Nozzles and Upper Shell Course One-Time 0

Demonstration (for License Renewal Commitment #19)

Corrective Action Corrective Action 03-03997, 03-04010, 08-03647, 15-03939, 17-03339, 18-

Documents Documents (by 05053, 18-05811, 19-00626, 19-02915, 19-03752, 20-00039,

number) 20-00673, 20-00908, 20-00911, 20-01972, 20-03563, 21-

013162, 21-013169, 21-02453, 21-02455, 21-02456, 21-

2457, 21-02858, 21-02859, 22-00114

Corrective Action Corrective Action 1190979, 1190982, 1191480, 1191649

Documents Documents

Resulting from generated during

Inspection inspection (by

number)

Drawings 1100E48 Tank Floor Drain 5

D-302-241 Station Service Air 31

D-302-242 Station Air Supply to Emergency Personnel and Equipment 8

Hatches

E-512-101 Auxiliary Building Stainless Steel lined Sumps & Floor Drains5

E-921-209 Auxiliary Building Floor Drains 5

Miscellaneous 1025323 Field Guide: Coating Assessment 05/01/2012

43047-RPT-01 V.C. Summer Plant Life Extension NFPA 805 Impact Review 1

51-9277547-000 Validation of V.C. Summer License Renewal Commitments 0

and Aging Management Program Credited Activities

Audit 21-07 Inservice Inspection, Inservice Testing and Appendix J 10/02/2021

Programs

TB-14-5 Reactor Internals Lower Radial Support Clevis Insert Cap 08/25/2014

Screw Degradation

Procedures B-817-056 Control Air Signal 14

CMP-400.001 Excavation Backfill and Earthwork 10B

CMP-500.003 APPLICATION AND REMOVAL OF PAINT ON SURFACES 11

OUTSIDE THE REACTOR BUILDING

ER-AA-101 System Engineering Walkdowns 5

ER-AA-BPM-101 Underground Piping and Tank Integrity Program 17

Inspection Type Designation Description or Title Revision or

Procedure Date

ER-AA-ISI-100 Dominion Inservice Inspection Program 12

ER-AA-MAT-11 Alloy 600 Management Program 17

ER-AA-NDE-UT-Ultrasonic Thickness Measurement Procedure 7

701

ER-AP-BAC-10 Boric Acid Corrosion Control Program 14

ER-AP-BAC-101 Boric Acid Corrosion Control Program (BACCP) Inspections14

ER-AP-BAC-102 Boric Acid Corrosion Control Program (BACCP) Evaluations15

ES-0163 One-Time Inspection Procedure for License Renewal 1

ES-0164 Selective Leaching Inspection Procedures for License 0

Renewal

ES-0165 Non-EQ Insulated Cables and Connections Inspection 0

Procedure for License Renewal

ES-0167 Non-EQ Instrumentation Cables and Connections Aging 1

Management Program for License Renewal

ES-0410 DOCUMENT ONLY CHANGE CONTROL 13

ES-0419 EQUAL TO/BETTER THAN (ETBT) EVALUATION 11

PROCESS

ES-0425 CUMULATIVE EFFECTS PROGRAM 4

ES-0451 STANDARD DESIGN PROCESS 1

ES-0453 DESIGN CONTROL: COMMERCIAL CHANGE 5

ES-0454 DESIGN CONTROL: PLANT ENHANCEMENT 3

ES-0455 DESIGN CONTROL: PLANT MODIFICATION 5

ES-0534 PLANT LIFE EXTENSION INSPECTIONS OF MECHANICAL 0

COMPONENTS

ES-536 Electric Cable Reliability Monitoring Program 1

ES-900 Fire Service Suppression System Corrosion Monitoring 1

Program

OAP-106.1 OPERATING ROUNDS 18

QSP-516 ULTRASONIC THICKNESS DETERMINATION 8

SAP-0133 DESIGN CONTROL/IMPLEMENTATION AND INTERFACE 16

SAP-0156 License Renewal Management Program 2

SAP-1258 Underground Piping and Tank Integrity Program (UPTIP)1A

SAP-1281 Alloy 600 Materials Reliability Program 1

Inspection Type Designation Description or Title Revision or

Procedure Date

SAP-1282 Electric Cable Reliability Monitoring Program 0

SAP-1294 Inservice Inspection Program 1

Work Orders Work Orders (by 1014124-001, 1014125-001, 1211069, 1510357,1510358,

number) 1707392-001, 1711480, 1711723, 1714002, 1703370,

1800479, 1802336, 1802338, 1812905, 1818757, 1906848-

001, 1906850-001, 1907523-005, 1908528, 2004039-001,

2011904-001, 2015720, 2015722, 2015723, 2015725,

2015727, 2100596-001, 2114805, 2114810, 2111421,

2111423, 2111424, 2111425, 2115794-001, 2115801-001,

88101037031, 88101037069, 88101037086, 88101037109,

8810101042148

11