IR 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:
Report Number:
Enterprise Identifier:
I-2022-010-0018
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
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
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
DC04030-003
Reactor Vessel Nozzles and Upper Shell Course One-Time
Demonstration (for License Renewal Commitment #19)
Corrective Action
Documents
Corrective Action
Documents (by
number)
03-03997, 03-04010, 08-03647, 15-03939, 17-03339, 18-
05053, 18-05811, 19-00626, 19-02915, 19-03752, 20-00039,
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
Documents
Resulting from
Inspection
Corrective Action
Documents
generated during
inspection (by
number)
1190979, 1190982, 1191480, 1191649
1100E48
Tank Floor Drain
D-302-241
Station Service Air
D-302-242
Station Air Supply to Emergency Personnel and Equipment
Hatches
E-512-101
Auxiliary Building Stainless Steel lined Sumps & Floor Drains
Drawings
E-921-209
Auxiliary Building Floor Drains
25323
Field Guide: Coating Assessment
05/01/2012
43047-RPT-01
V.C. Summer Plant Life Extension NFPA 805 Impact Review
51-9277547-000
Validation of V.C. Summer License Renewal Commitments
and Aging Management Program Credited Activities
Audit 21-07
Inservice Inspection, Inservice Testing and Appendix J
Programs
10/02/2021
Miscellaneous
TB-14-5
Reactor Internals Lower Radial Support Clevis Insert Cap
Screw Degradation
08/25/2014
B-817-056
Control Air Signal
CMP-400.001
Excavation Backfill and Earthwork
10B
CMP-500.003
APPLICATION AND REMOVAL OF PAINT ON SURFACES
OUTSIDE THE REACTOR BUILDING
System Engineering Walkdowns
71003
Procedures
ER-AA-BPM-101
Underground Piping and Tank Integrity Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ER-AA-ISI-100
Dominion Inservice Inspection Program
ER-AA-MAT-11
Alloy 600 Management Program
ER-AA-NDE-UT-
701
Ultrasonic Thickness Measurement Procedure
ER-AP-BAC-10
Boric Acid Corrosion Control Program
ER-AP-BAC-101
Boric Acid Corrosion Control Program (BACCP) Inspections
ER-AP-BAC-102
Boric Acid Corrosion Control Program (BACCP) Evaluations
One-Time Inspection Procedure for License Renewal
Selective Leaching Inspection Procedures for License
Renewal
Non-EQ Insulated Cables and Connections Inspection
Procedure for License Renewal
Non-EQ Instrumentation Cables and Connections Aging
Management Program for License Renewal
DOCUMENT ONLY CHANGE CONTROL
EQUAL TO/BETTER THAN (ETBT) EVALUATION
PROCESS
CUMULATIVE EFFECTS PROGRAM
STANDARD DESIGN PROCESS
DESIGN CONTROL: COMMERCIAL CHANGE
DESIGN CONTROL: PLANT ENHANCEMENT
DESIGN CONTROL: PLANT MODIFICATION
PLANT LIFE EXTENSION INSPECTIONS OF MECHANICAL
COMPONENTS
Electric Cable Reliability Monitoring Program
Fire Service Suppression System Corrosion Monitoring
Program
OAP-106.1
OPERATING ROUNDS
QSP-516
ULTRASONIC THICKNESS DETERMINATION
DESIGN CONTROL/IMPLEMENTATION AND INTERFACE
License Renewal Management Program
Underground Piping and Tank Integrity Program (UPTIP)
1A
Alloy 600 Materials Reliability Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Electric Cable Reliability Monitoring Program
Inservice Inspection Program
Work Orders
Work Orders (by
number)
1014124-001, 1014125-001, 1211069, 1510357,1510358,
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