ML19128A079
| ML19128A079 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/30/2019 |
| From: | Sayoc E NRC/NRR/DMLR/MRPB |
| To: | Stoddard D Dominion Energy Virginia, Virginia Electric & Power Co (VEPCO) |
| Sayoc E, DMLR/MRPB, 301-287-3716 | |
| References | |
| EPID L-2018-RNW-0023, EPID L-2018-RNW-0024 | |
| Download: ML19128A079 (134) | |
Text
May 30, 2019 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd Glen Allen, VA 29060
SUBJECT:
SURRY POWER STATION, UNITS NOS. 1 AND 2 - REPORT FOR THE IN-OFFICE REGULATORY AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NOS. L-2018-RNW-0023 AND L-2018-RNW-0024)
Dear Mr. Stoddard:
By letter dated October 15, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18291A842), as supplemented by letters dated January 29, 2019 (ADAMS Accession No. ML19042A137), and April 2, 2019 (ADAMS Accession No. ML19095A666), Virginia Electric and Power Company (Dominion Energy Virginia or Dominion) submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Renewed Facility Operating License Nos. DPR-32 and DPR-37 for the Surry Power Station, Unit Nos. 1 and 2. Dominion submitted the application pursuant to Title 10 of the Code of Federal Regulations Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for subsequent license renewal.
The NRC staff completed its in-office regulatory audit from February 4 - 28, 2019, in accordance with the in-office regulatory audit plan (ADAMS Accession No. ML19015A243). The audit report is enclosed.
If you have any questions, please contact me by telephone at 301-415-4084 or by e-mail at Emmanuel.Sayoc@nrc.gov.
Sincerely,
/RA/
Emmanuel Sayoc, Project Manager License Renewal Project Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281
Enclosure:
Audit Report cc w/encl: Listserv
ML19128A079 OFFICE PM:MRPB:DMLR PM:MRPB:DMLR LA:MRPB:DMLR BC:MRPB:DMLR NAME AWu ESayoc YEdmonds EOesterle DATE 4/24/2019 5/14/2019 5/23/2019 5/23/2019 OFFICE PM:MRPB:DMLR PM:MRPB:DMLR NAME AWu ESayoc DATE 5/29/2019 5/30/2019
Audit Report In-Office Regulatory Audit Surry Power Station, Unit Nos. 1 and 2, Subsequent License Renewal Application February 4 - 28, 2019 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket Nos:
50-280 and 50-281 License No:
Virginia Electric and Power Company (Dominion Energy Virginia)
Facility:
Surry Power Station, Unit Nos. 1 and 2 Location:
Rockville, Maryland Dates:
February 4 - 28, 2018 Reviewers:
B. Allik, Materials Engineer, Division of Materials and License Renewal (DMLR)
A. Buford, Structural Engineer, Division of Engineering (DE)
A. Chereskin, Chemical Engineer, DMLR G. Cheruvenki, Materials Engineer, DMLR S. Cuadrado de Jesus, Structural Engineer, DE R. Davis, Senior Materials Engineer, DMLR D. Dijamco, Materials Engineer, DMLR B. Fu, Materials Engineer, DMLR W. Gardner, Physical Scientist, DMLR J. Gavula, Mechanical Engineer, DMLR D. Hoang, Structural Engineer, DE K. Hoffman, Materials Engineer, DMLR W. Holston, Senior Mechanical Engineer, DMLR A. Huynh, Materials Engineer, DMLR N. Iqbal, Fire Protection Engineer, Division of Risk Assessment A. Johnson, Materials Engineer, DMLR R. Kalikian, Materials Engineer, DMLR J. Lopez, Structural Engineer, DE J. Medoff, Senior Materials Engineer, DMLR S. Min, Materials Engineer, DMLR D. Murray, Electrical Engineer, DE D. Nguyen, Electrical Engineer, DE D. Nold, Reactor Systems Engineer, DSS A. Prinaris, Structural Engineer, DE S. Ray, Electrical Engineer, DE A. Rezai, Materials Engineer, DMLR M. Sadollah, Electrical Engineer, DE R. Pettis, Senior Reactor Engineer, DE S. Peng, Reactor Systems Engineer, DSS A. Prinaris, Structural Engineer, DE G. Thomas, Senior Structural Engineer, DE J. Tsao, Senior Materials Engineer, DMLR A. Young, Materials Engineer, DMLR G. Wang, Structural Engineer, DE
Approved By:
David Alley, Chief Vessels & Internals Branch Division of Materials and License Renewal Steve Bloom, Chief Chemical, Corrosion, & Steam Generator Branch Division of Materials and License Renewal Eric Oesterle, Chief License Renewal Projects Branch Division of Materials and License Renewal Stephen Cumblidge, Acting Chief Piping & Head Penetration Branch Division of Materials and License Renewal Shaun Anderson, Chief Balance of Plant Branch Division of Safety Systems Jennifer Whitman, Chief Reactor Systems Branch Division of Safety Systems Greg Casto, Chief PRA Licensing Branch B Division of Engineering Tania Martinez-Navedo, Chief Electrical Engineering, New Reactors, & License Renewal Branch Division of Engineering Brian Wittick, Chief Structural Engineering Branch Division of Engineering Report for the In-Office Regulatory Audit Surry Power Station, Unit Nos. 1 and 2 Subsequent License Renewal Application
- 1. Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an in-office audit of Virigina Electric and Power Company (Dominion Energy Virginia or Dominion) (1) methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR) (Scoping and Screening Portion), and (2) aging management programs (AMPs), AMR items, Time-Limited Aging Analyses (TLAA) and associated bases and documentation as applicable (AMP and TLAA Portion) for the subsequent license renewal of Renewed Facility Operating License Nos.
DPR-32 and DPR-37 for Surry Power Station, Unit Nos. 1 and 2 (SPS or the applicant).
The purpose of the Scoping and Screening Portion of the audit is to evaluate the scoping and screening process as documented in the license renewal application, implementing procedures, reports, and drawings, such that the NRC staff:
Obtains an understanding of the process used to identify the SSCs within the scope of license renewal and to identify the structures and components subject to an aging management review.
Has sufficient docketed information to allow the staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied.
The purpose of the AMP and TLAA Portion of the audit is to:
Examine Dominions AMPs, AMR items, and TLAAs for SPS; Verify Dominions claims of consistency with the corresponding NUREG-2191, Rev. 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued in July 2017, AMPs, and AMR items; and Assess the adequacy of the TLAAs.
Enhancements and exceptions will be evaluated on a case-by-case basis. The NRC staffs review of enhancements and exceptions will be documented in the safety evaluation report.
NUREG-2192, Rev. 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, issued in July 2017 (SRP-SLR), provides staff guidance for reviewing a subsequent license renewal application. The SRP-SLR allows an applicant to reference in its license renewal application the AMPs described in GALL-SLR Report. By referencing the GALL-SLR Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL-SLR Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL-SLR Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL-SLR Report program. The applicant should document this determination in an auditable form and maintain the documentation onsite.
- 2. Audit Activities A regulatory audit is a planned, license-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain greater understanding of an application, to verify information, and/or to identify information that will require docketing to support the staffs conclusions that form the basis of the licensing or regulatory decision.
Licensing conclusions or staff findings should not be made in the audit reports since licensing and regulatory decisions cannot be made solely based on an audit. Therefore, items identified but not resolved within the scope of the audit will be followed using other NRC processes, such as requests for additional information (RAIs), requests for confirmation of information, and public meetings. Licensing conclusions, staff findings, and resolution of audit items will be documented in the staffs safety evaluation report (SER).
The following sections discuss the subsequent license renewal application (SLRA) areas reviewed by the staff.
SLRA AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Summary of Information in the Application. The SLRA states that AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD is an existing program that will be consistent with the program elements in GALL SLR Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. To verify this claim of consistency, the staff audited the SLRA AMP.
Audit Activities. During the NRC audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant.
The table below lists documents that were reviewed by the staff and were found relevant to the audit.
Relevant Documents Reviewed Document Title Revision / Date CR 1065913 ISI AMP Effectiveness Summary 10/16/2017 PIR 1079417 ISI Program Self Assessment 02/15/2018 CR 357794 Rejectable PT Exam 11/12/2009 CR 402204 Unaccepable PT indication 11/03/2010 CR 503773 PT Indications Identified during Weld Exam 10/28/2013 CR 1076642 Review for Commitments 08/28/2017 CR 359010 Weld Not Found in Field 12/20/2009 CR 403659 Rejected Weld 11/04/2010
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL SLR Report AMP.
During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. However, the staff identified issues related to the review of the SLRA and database search on operating experience that require further clarification. The staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.
The staff also audited the description of the SLRA AMP provided in the Updated Final Safety Analysis Report (UFSAR) supplement. The staff verified that this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.2, Water Chemistry Summary of Information in the Application. The SLRA states that AMP B.2.1.2, Water Chemistry, is an existing program with exceptions that is consistent with the program elements in GALL-SLR Report AMP XI.M2, Water Chemistry. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exceptions associated with this AMP. The staff will document its review of the exceptions to the GALL-SLR Report AMP in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1305 Subsequent License Renewal Project Aging Management Program Evaluation Report - Water Chemistry Revision 1 ETE-SLR-2018-1305 Subsequent License Renewal Project Aging Management Program Evaluation Report - Water Chemistry Revision 2 CH-99.500 Primary Chemistry Program Revision 13 CH-99.502 Primary Chemistry Strategic Water Plan Revision 0 CH-99.600 Secondary Chemistry Specifications and Action Levels Revision 16 CH-99.602 Secondary Chemistry Strategic Water Plan Revision 0 CY-AA-100 Conduct of Chemistry Revision 12 CY-AP-PRI-100 Primary System Chemistry Revision 10
Document Title Revision / Date CY-AP-SEC-200 Secondary System Chemistry Revision 7 ER-AP-SGP-101 Steam Generator Program Revision 12 EPRI MRP Report No.
1016555 Pressurized Water Reactor Secondary Water Chemistry Guidelines Revision 7 EPRI MRP Report No.
3002000505 Pressurized Water Reactor Primary Water Chemistry Guidelines Revision 7 EPRI MRP Report No.
3002010645 Pressurized Water Reactor Secondary Water Chemistry Guidelines Revision 8 N/A Primary Trend Reports 4/15/2015 N/A Secondary Trend Reports 4/28/2016 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, and preventive actions, program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also verified Dominions claim that aspects of the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements not associated with the exception identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.4, Boric Acid Corrosion Summary of Information in the Application. The SLRA states that AMP B.2.1.4, Boric Acid Corrosion, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M10, Boric Acid Corrosion. To verify this claim of consistency, the staff audited the SLRA AMP.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ER-AP-BAC-10 Boric Acid Corrosion Control Program Revision 12 1-PT-36-LOG1R Unit 1 Operations Normal Log #1 Revision 30 0-NSP-RM-001 Radiation Monitor Trending Revision 4 2-PT-36-LOG1R Unit 2 Operations Normal Log #2 Revision 29 0-NSP-VS-003 Containment Ventilation System Inspection Revision 7 1-OPT-RC-10.0 Reactor Coolant Leakage - Computer Calculated Revision 47 2-OPT-RC-10.0 Reactor Coolant Leakage - Computer Calculated Revision 44 ER-AP-BAC-101 Boric Acid Corrosion Control Program (BACCP) Inspections Revision 12 1-OPT-RC-10.1 Reactor Coolant Leakage Walkdown at Cold Shutdown Revision 11 ER-AP-BAC-102 Boric Acid Corrosion Control Program (BACCP) Evaluations Revision 13 MA-AA-1002 Leakage Management Revision 6 Letter 88-170A Virginia Electric and Power Company Surry Power Station Units 1 and 2 Response to Generic Letter 88-05 6/03/88 ETE-SLR-2018-1307 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Boric Acid Corrosion Revision 1 N/A 1R28 BACC Leak List Start-up Assessment 05/13/2018 N/A 2R28 BACC Leak List Start-up Assessment 12/01/2018 MA-AA-1002 Leakage Management Revision 6 ER-AP-1 Management and Resolution of Boric Acid Leakage Revision 1 ER-AA-106 Evaluation, Review, and Approval of Injection-Type Leak Sealing Revision 1 MA-AA-MCM-ILS-101 Injection-Type Leak Sealing Revision 1 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Boric Acid Corrosion program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.6, Thermal Aging Embrittlement of Cass Austenitic Stainless Steel (CASS)
Summary of Information in the Application. The SLRA states that AMP B.2.1.6, Thermal Aging Embrittlement of Cass Austenitic Stainless Steel (CASS) is an existing program that will be consistent with the program elements in GALL SLR Report AMP XI.M12, Thermal Embrittlement of Cass Austenitic Stainless Steel (CASS). To verify this claim of consistency, the staff audited the SLRA AMP.
Audit Activities. During the NRC audit, the staff reviewed the applicants document in its portal and discussed with applicant the technical issues related to the AMP.
The table below lists the document that was reviewed by the staff and was found relevant to the audit.
Relevant Documents Reviewed Document Title Revision / Date WCAP-18258 Flaw Tolerance Evaluation for Susceptible Reactor Coolant Loop Cast Austenitic Stainless Steel Elbow Components for Surry Units 1 and 2.
Revision 0 December2017 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL SLR Report AMP.
During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. However, the staff identified issues related to the review of the WCAP-18258 report that require further clarification. The staff will consider issuing an RAI. The staffs evaluation of these potential RAIs will be documented in the SER.
The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
The staff verified that this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.7, PWR Vessel Internals Summary of Information in the Application. The SLRA states that AMP B.2.1.7, PWR Vessel Internals, is an existing program, with enhancements, will be consistent with the program elements in GALL-SLR AMP XI.M16A, PWR Vessel Internals. To verify this claim of consistency, the staff audited the SRLA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with the AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. The scope of the staffs audit included a review of the program described in SLRA Section B.2.1.7 and the updated final safety analysis report (UFSAR) for the AMP provided in SLRA Section A1.7. The scope of the staffs audit also included a review of the applicants responses to the Applicant/Licensee Action Items (A/LAIs) on the MRP-227-A methodology, the applicants gap analysis and gap analysis results that were provided in Appendix C of the SLRA and supporting background documents and reports.
During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision/Date EPRI MRP Report No.
1022863 Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A)
Revision 0, December 2011 EPRI MRP Report No.
1012081 Materials Reliability Program: PWR Internals Material Aging Degradation Mechanism Screening and Threshold Values (MRP-175)
Revision 0 December 2005 EPRI MRP Report No.
3002010268 Materials Reliability Program: PWR Internals Material Aging Degradation Mechanism Screening and Threshold Values (MRP-175, Revision 1)
Revision 1 October 2017 EPRI MRP Report No.
3002007960 Materials Reliability Program: Screening, Categorization, and Ranking of Reactor Internals Components for Westinghouse and Combustion Engineering PWR Design (MRP-191, Revision 1)
Revision 1 October 2016 EPRI MRP Report No.
3002005349 Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227, Revision 1)
Revision 1 October 2015 EPRI MRP Report No.
3002005386 Materials Reliability Program: Inspection Standard for Pressurized Water Reactor Internals - 2015 Update Revision 2 December 2015 Dominion Calculation No. PM-1634 Derivation of North Anna and Surry Units 1 and 2 Inputs for MRP-227-A Fluence Assessment (MRP-228, Rev. 2)
Revision 0 April 14, 2014
Document Title Revision/Date Westinghouse Electric Company Letter No.
LTR-AMLR-17-35-NP Transmittal of Preliminary Results from the MRP-191 Expert Panel Review in Support of Subsequent License Renewal for Surry Units 1 and 2 Revision 0 September 19, 2018 EPRI MRP Letter No.
MRP-2018-022 Transmittal of MRP-191-SLR Screening, Ranking, and Categorization Results and Interim Guidance in Support of Subsequent License Renewal at U.S. PWR Plants August 31, 2018 EPRI MRP Letter No.
MRP-2018-027 NEI 03-08 Needed Inspection Guidance for PWR CRDM Thermal Sleeve Wear August 31, 2018 Westinghouse Electric Company Nuclear Safety Advisory Letter No.
NSAL-18-1 Thermal Sleeve Flange Wear Leads to Stuck Control Rod July 9, 2018 Westinghouse Electric Company Nuclear Safety Advisory Letter No.
NSAL-16-1 Baffle-Former Bolts Revision 1 August 1, 2016 Westinghouse Electric Company Technical Bulletin No. TB-16-4 Fuel Alignment Pin Malcomized Surface Degradation August 19, 2016 ERPI MRP Letter No.
MRP-2013-025 MRP-227-A Applicability Template and Guideline Oct. 14, 2013 ERPI MRP Letter No.
MRP-2017-009 Transmittal of NEI-03-08 Needed Interim Guidance Regarding Baffle Former Bolt Inspections for PWR Plants as Defined in Westinghouse NSAL 16-01, Rev. 1 March 15, 2017 ERPI MRP Letter No.
MRP-2018-007 Transmittal of NEI-03-08 Needed Interim Guidance to Address Accelerated Guide Card Wear Operating Experience (OE)
Discussed in NSAL-17-1 March 7, 2018 EPRI MRP Letter No.
MRP-2018-010 Notification of Recent PWR CRDM Thermal Sleeve Wear and Control Rod Motion Stoppage Operating Experience and Recommended Actions April 20, 2018 Westinghouse Electric Company Proprietary Report No. WCAP-17451-P Reactor Internals Guide Tube Wear - Westinghouse Domestic Fleet Operational Projections Revision 1 October 2013 Westinghouse Electric Company Non-Proprietary Report No. WCAP-17096-NP Reactor Internals Acceptance Criteria Methodology and Data Requirements Revision 2 December 2009
Document Title Revision/Date Westinghouse Electric Company Proprietary Report No. WCAP-17289-P Determination of Acceptable Baffle-Barrel Bolting for Surry Units 1 and 2 Revision 0-A August 2010 Dominion-Specific Record for Surry Station ALAI 1 thru 8 Evaluations No Revision or Date Specified Dominion Energy Engineering and Technical Evaluation No.
ETE-SLR-2018-1310 Surry Subsequent License Renewal Project - Aging Management Program Evaluation - PWR Vessel Internals Revision 1 Dominion Serial Letter No.19-096 Virginia Electric and Power Company, Surry Power Station (SPS) Units 1 and 2, Supplement to Subsequent License Renewal Application, Change Notice 2 (Including Enclosures 1 and 2 in the letter, ADAMS Nos. ML19095A597, ML19095A600, and ML19095A602)
April 2, 2019 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed ETE-SLR-2018-1310, Revision 1, and noted that the applicants program is based on the methodology in EPRI Report MRP-227-A, as amended by the gap analysis assessment that the applicant included Appendix C of the SLRA. The staff noted that the applicant used the updated basis in ERPI MRP Report No. MRP-227, Revision 1, EPRI MRP Letter 2018-022, and Westinghouse Letter No. LTR-AMLR 35-NP, Revision 1, or other supporting documents as the basis for performing the programmatic gap analysis. The staff observed that the gap analysis was included in the SLRA to identify those programmatic changes that would need to be made to the program based on an 80-year assessment, as compared to the original programmatic criteria defined for the program in accordance with the MRP-227-A report. The staff noted that this basis is consistent with the scope of program element criterion defined in GALL-SLR AMP XI.M16A.
The staff reviewed Dominion Calculation PM-1634 and the applicants responses to the A/LAIs on MRP-227-A. The staff observed that the calculation provides sufficient demonstration that the heat generation merit values, average core power density values, and core height distance values for the units are bounded by the threshold values set for these parameters in EPRI MRP Letter No. 2013-025. The staff also observed that this provides evidence that the design of the RVI components in Units 1 and 2 are bounded by the generic designs evaluated in MRP-227-A, with the exception of those changes that are being made to this the program based on the results of the applicants gap analysis.
The staff observed that several matters in the gap analysis will need to be addressed either as part of the audit review or the formal review of the AMP:
o Control rod guide tube (CRGT) assembly components - guide cards, C-tubes and sheaths. The staff observed that additional clarifications may be necessary on whether the control rod guide tube (CRGT) C-tubes and sheaths should be designated as Expansion category components, as based on the Expansion category criteria specified for the components on page 5-23 of WCAP-17451P, Revision 1. Additionally, the staff observed that additional clarifications may be necessary on whether the CRGT sheaths should be considered for inclusion in Primary category of components based on their high 80-year likelihood of failure and safety consequence rankings for the sheaths, and their safety consequence risk category ranking designation of C.
o CRGT assembly components - CRGT flexures at Unit 1. The staff observed that the CRGT flexures at Unit 2 are made from X-750 Nickel-based alloy materials and that the components screened in for SCC and fatigue aging mechanisms. The staff noted that the gap analysis results for the flexures placed the components in the No Additional Measures category based on the updated, 80-year gap analysis rankings for the components. The staff observed that additional clarifications may be needed on whether the CRGT flexures (Unit 1 only) should be considered for inclusion in the Primary category based on the safety consequence risk category ranking for the components, which is C.
o Upper core plate (UCP) and lower core plate (LCP) assembly components - fuel alignment pins. The staff observed that the UCP and LCP fuel alignment pins were included in the Existing Program category of components based on the applicable aging mechanisms for the pins (i.e., IASCC, wear, fatigue, and IE for the UCP fuel alignment pins and IASCC, wear, IE, and void swelling [VS] for the LCP fuel alignment pins) and the component-specific rankings for the pins over an 80-year evaluation basis. The staff noted that SLRA Table 4.3-3 identifies that VT-3 visual examinations will be performed on the UCP fuel alignment pins and LCP fuel alignment pins during the subsequent period of extended operation. The staff observed that additional clarifications may be needed on whether these VT-3 methods are capable of detecting evidence of IASCC-induced or fatigue-induced cracking in the components.
o Core barrel assembly components - core barrel flanges. The staff observed that, in SLRA Table C3.3-3, the core barrel flanges were included in the Primary category of components based on the applicable aging mechanisms for the flanges (i.e., SCC-W and wear) and the component-specific rankings for the flanges over an 80-year evaluation basis. However, the staff noted that SLRA Table C4.3-1, Primary Components, did not include a component-specific line item for the core barrel flanges. The staff observed that additional clarifications may be needed on whether SLRA Table C4.3-1 should be amended to include a component-specific line item for the core barrel flanges.
o Core barrel assembly components - lower flange welds (LFWs) and upper girth welds (UGWs). The staff observed that the applicant would need to address whether the core barrel assembly LFWs and UGWs are designated as Primary category components for the programmatic basis or Expansion category components for the
programmatic basis. The staff observed that SLRA Table C3.3-3 identifies that the LFWs and UGWs are Primary category components for the 80-year basis. In contrast, the staff observed that SLRA Table C4.3-2 identifies that the LFWs and UGWs are Expansion category components for the 80-year basis.
o Core barrel assembly components - core barrel outlet nozzles. The staff observed that, in SLRA Table C3.3-3, the core barrel outlet nozzles were included in the Primary category of components based on the applicable aging mechanisms for the flanges (i.e., SCC-W and wear) and the component-specific rankings for the nozzles over an 80-year evaluation basis. However, the staff noted that SLRA Table C4.3-2, Expansion Components, did not include a component-specific line item for the core barrel outlet nozzles. The staff observed that additional clarifications may be needed on whether SLRA Table C4.3-2 should be amended to include a component-specific line item for the core barrel outlet nozzles.
o Lower support assembly - lower support column bodies. The staff observed that, in SLRA Table C3.3-3, the lower support column bodies were included in the Expansion category of components based on the applicable aging mechanisms for the flanges (i.e., IASCC, fatigue, TE, IE, and VS) and the component-specific rankings for the nozzles over an 80-year evaluation basis. The staff also observed that in SLRA Table C4.3-2, the applicant identifies that VT-3 visual examinations will be performed on the components during the subsequent period of extended operation. However, the staff noted that Table C4.3-1 indicates that the visual inspection technique applied to the linked Primary category component (i.e., those proposed for the core barrel assembly lower girth welds [LGWs]) will be an EVT-1 visual method. The staff observed that the applicant would need to justify why the proposed visual technique for the column bodies is a VT-3 visual method rather than an EVT-1 visual inspection method.
o Lower internals assembly - radial support keys. The staff observed that, in SLRA Table C3.3-3, the radial support keys were included in the Primary category of components based on the applicable aging mechanisms for the keys (i.e., SCC-W, fatigue, and wear) and the component-specific rankings for the radial support keys over an 80-year evaluation basis. The staff noted that SLRA Table 4.3-1 identifies that VT-3 visual examinations will be performed on the radial support key surfaces during the subsequent period of extended operation. The staff observed that additional clarifications may be needed on whether these VT-3 methods are capable of detecting evidence of SCC-induced or fatigue-induced cracking in the components.
On April 2, 2019, Dominion submitted an amendment of the SLRA, which includes proposed changes to the SRLA to address matters raised in the observations paragraphs listed above.
The staff will review the SLRA changes proposed in the SLRA amendment of April 2, 2019, as part of the staffs formal review of SLRA AMP B.2.1.7, PWR Vessel Internals. Any matters needing further resolution by the applicant will be subject to a request for additional information (RAI) to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP. The staffs review and evaluation of the PWR Vessel Internals Program will be documented in the staffs safety evaluation report (SER) for the application.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff verified that the applicants program has been adjusted to account for existing operating experience (OpE) in PWR RVI components, including but not limited to OpE events associated with: (a) cracking in baffle-former bolts or other baffle-former assembly bolts, (b) wear in CRGT guide cards, and (c) cracking in Westinghouse-design clevis insert assemblies. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the UFSAR supplement summary description of the PWR Vessel Internals Program provided in SLRA Section A1.7. The staff verified this description is consistent with the description provided for PWR Vessel Internals Programs in Table 3.0-1 of the GALL-SLR Report.
SLRA AMP B.2.1.8, Flow-Accelerated Corrosion Summary of Information in the Application. The SLRA states that AMP B.2.1.8, Flow-Accelerated Corrosion, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M17, Flow-Accelerated Corrosion. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ER-AA-FAC-10 Flow Accelerated Corrosion Program Revision 7 ER-AA-FAC-102 FAC Inspection and Evaluation Activities Revision 0 ER-AA-FAC-105 Erosion Control Program Revision 0 ETE-SLR-2018-1311 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Flow-Accelerated Corrosion Revision 1 ME-0133 Surry Unit 1 - FAC Susceptibility Analysis Revision 1 ME-0134 Surry Unit 2 - FAC Susceptibility Analysis Revision 1 WO-38103797602 Piping Replacement Revision 0 SQA-CHECWORKS-20140107 CHECWORKS-SFA Version 4.0 SP-1 01/07/2014 IT-AA-SQA-101 Software Quality Assurance Revision 7
Document Title Revision / Date GMP-006 Removal and Replacement of Piping Systems Revision 16 ER-AA-FAC-1001 Flow-Accelerated Corrosion (FAC) Susceptibility Analysis &
Modeling Revision 6 DRAFT ER-AA-FAC-104 Crossover/Crossunder Inspection & Evaluation Activities Revision 0 ETE-CME-2019-0002 Surry Unit 1, 2018 Refueling Outage, Results of the Flow Accelerated Corrosion Program Revision 0 ETE-CME-2019-0008 Surry Unit 1, 2016 Refueling Outage, Results of the Flow Accelerated Corrosion Program Revision 0 WO-38203876495 DC SU-17-00125 FAC: Replace 5 MS components on gland steam supply line Revision 0 CR-1096902 Significant Wear Observed during FAC Inspection (5-SGS 151)
Revision 0 ETE-CME-2017-0013 Surry Unit 2, 2017 Refueling Outage, Results of the Flow Accelerated Corrosion Program Revision 0 ETE-CME-2018-1002 Transmittal of True North Consulting Technical Report BP-2017-0045-TR-01, Erosion Susceptibility Evaluation (ESE) -
Surry Unit 1 Revision 1 ETE-CME-2018-1003 Transmittal of True North Consulting Technical Report BP-2017-0045-TR-02, Erosion Susceptibility Evaluation (ESE) -
Surry Unit 2 Revision 1 ETE-CME-2019-1001 Transmittal of True North Consulting Technical Report BP-2018-0007-TR-01, Unit 1 FAC System Susceptibility Evaluation (SSE) and Susceptible Non-Modeled (SNM) Heating Steam (HS//0 System Update Revision 0 PA7463069 Benchmark lessons learned from IP3 FAC Failure on 6 elbow 2/21/2019 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, and monitoring and trending, program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed documents and ER-AA-FAC-10 and ER-AA-FAC-102 and noted that certain requirements in these procedures appear to apply to the erosion program.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP Flow-Accelerated Corrosion provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.9, Bolting Integrity Summary of Information in the Application. The SLRA states that AMP B.2.1.9, Bolting Integrity, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M18, Bolting Integrity. To verify this consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP.
The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1312 Subsequent License Renewal Project Aging Management Program Evaluation Report Bolting Integrity Surry Power Station Revision 1 N/A Surry Power Station Units 1 and 2 Application for Subsequent License Renewal October 2018 ER-AA-ISI-100 Dominion Inservice Inspection Program Revision 10 ER-AA-SPT-100 ASME Section XI System Pressure Test Program Fleet Implementation Requirements Revision 6 0-MCM-1004-01 Bolted Connection Disassembly and Reassembly Revision 21 ER-SU-5806 Torque Control Program Revision 9 MA-AA-100 Conduct of Maintenance Revision 17 ER-AA-101 System Engineering Walkdown Revision 2 0-MCM-1001-01 Threaded Fastener Inspection and Replacement, Mechanical Corrective Maintenance, Surry Power Station Revision 13 1-OPT-RC-10.1 Reactor Coolant Leakage Walkdown at Cold Shutdown, Operations Periodic Test Revision 11 ER-AA-NDE-140 Nondestructive Examination Procedure Revision 5
Document Title Revision / Date 0-MPM-1901-02 Low Level Intake Structure Screenwells 1D, 2A, 2B Service Water Inspection, Mechanical Preventive Maintenance Procedure Revision 9 SPS UFSAR Surry Power Station Updated Final Safety Analysis Report 2017 1-NPT-LR-001 License Renewal General Condition Monitoring Review -
Unit 1 Containment, Engineering Periodic Test, Surry Power Station Revision 1 2-NPT-LR-001 License Renewal General Condition Monitoring Review -
Unit 1 Containment, Engineering Periodic Test, Surry Power Station Revision 1 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of the program, preventive actions, parameters monitored or inspected, monitoring and trending, detection of aging effects, acceptance criteria, and corrective actions, program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed SPS SLRA Section B.2.1.9 and noted that it states that only the air sub-systems require aging management since the hydrogen gas sub-system is not in the scope of components requiring aging management for SLR. However, the staff noted that SLRA Sections 2.3.3.35, Hydrogen Gas, 3.3.2.1.35, Hydrogen Gas, and respective Table 3.3.2-35, describe the hydrogen gas system as one within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) for spatial interaction and also include AMRs for the management of aging effects (loss of material and loss of preload) of closure bolts on this system. Based on information in the SLRA and audited documents it is not clear whether the hydrogen gas sub-system and hydrogen gas system are either the same system or different systems. If the systems are the same clarification is needed to resolve the scoping contradictory statements and information in the SLRA. If these are different systems, the staff may need additional information regarding a description of the hydrogen gas sub-system and the basis for it to be considered out of scope for SLR. During an interview with the applicant the Dominion staff clarified that the hydrogen gas sub-system is the same as the hydrogen gas system. The applicant also clarified that the statement in SLRA Section B.2.1.9 was incorrect because the hydrogen gas sub-system is in scope of SLR. The Dominion staff also stated that a supplement to the SLRA will be issued to remove the contradictory statement from SLRA Section B.2.1.9.
The staff reviewed SPS SLRA Section A1.9 (AMP UFSAR Supplement) and noted that it is not consistent with the following statement in the GALL-SLR Report Table XI-01 (FSAR supplement recommendation), The program includes periodic visual inspection of closure bolting for indications of loss of preload, cracking, and loss of material due to general, pitting, and crevice corrosion, MIC, and wear as evidenced by leakage. The SLRA UFSAR has no mention of periodic visual inspections to identify evidence of leakage. The staff needs clarification on this inconsistency with the GALL-SLR Report Table XI-01. During an interview with the applicant the Dominion staff stated that a supplement to the SLRA will be
issued to incorporate the referenced wording and therefore make the AMP UFSAR supplement consistent with the GALL-SLR Report Table XI-01.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the Bolting Integrity Program. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
SLRA AMP B.2.1.10, Steam Generators Summary of Information in the Application. The SLRA states that AMP B.2.1.10, Steam Generators, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M19, Steam Generators. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1313 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Steam Generators Revision 1 03-1250267-003 Steam Generator Upper Internals Inspection Procedure for Recirculating Steam Generators Revision 0 03-1274768-003 Secondary Side Visual Inspection and Loose Part Retrieval Procedure for Heat Exchangers Revision 0 0-OSP-RC-002 Steam Generator Primary to Secondary Leakage Monitoring Revision 18 54-ISI-400-022 Non-Destructive Examination Procedure Multi-Frequency Eddy Current Examination Tubing Revision 0 CH-99.500 Primary Chemistry Specifications and Action Levels Revision 14 CH-99.600 Secondary Chemistry Specifications and Action Levels Revision 16 CY-AP-PRI-100 Primary System Chemistry Revision 10 CY-AP-SEC-200 Secondary System Chemistry Revision 7 ER-AA-ISI-100 Dominion Inservice Inspection Program Revision 10
Document Title Revision / Date ER-AA-MAT-11 Alloy 600 Management Plan Revision 15 ER-AP-SGP-10 Steam Generator Program Description Revision 8 ER-AP-SGP-101 Steam Generator Program Revision 12 ER-AP-SGP-102 Steam Generator Degradation Assessment Revision 8 ER-AP-SGP-103 Steam Generator Condition Monitoring and Operational Assessments Revision 7 MA-AA-102 Foreign Material Exclusion Revision 22 ETE-SU-2018-0010 Steam Generator Condition Monitoring and Operational Assessment Surry Unit 1 - Spring 2018 Revision 0 ETE-SU-2018-0042 Steam Generator Degradation Assessment Surry Unit 2 Refueling Outage 2R28 Revision 0 N/A Surry Units 1 and 2 Technical Specifications N/A N/A Updated Final Safety Analysis Report Revision 49 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the SLRA discussion of Further Evaluation (FE) item 3.1.2.2.11(1), Cracking due to Primary Water Stress Corrosion Cracking, sufficient information was not available to determine whether the applicant provided a sufficient evaluation for the SRP-SLR Report FE item. The staff will consider issuing an RAI to obtain the information necessary to verify whether the corresponding AMR item is consistent the SRP-SLR Report.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Steam Generator program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.11, Open-Cycle Cooling Water System Summary of Information in the Application. The SLRA states that AMP B.2.1.11, Open-Cycle Cooling Water System, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M20, Open-Cycle Cooling Water System. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER. During the audit, the staff reviewed the
exception and enhancements to the GALL-SLR Report AMP and will document its evaluation of Dominions bases in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominion personnel and reviewed documentation provided by them. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1314 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Open-Cycle Cooling Water System Revision 2 ETE-SU-2018-1004 Service Water Inspection Activities, License Renewal Aging Management Activities (LR-1754)
Revision 0 DC-SU-17-00100 Circulating and Service Water Inlet Pie - CRFP Repair Revision 6 DC-SU-15-01107 MER-3 & 4 Service Water Improvements Revision 17 DC-SU-14-00006 Circulating and Service Water CFRP Pipe Repair Revision 0 0-NSP-SW-001 Selected Service Water System Piping Wall Thickness Monitoring Revision 4 ER-SU-AUG-101 Surry Augmented Inspection Program Revision 17 CA3022000 Charging Pump Lube Oil Commitment Change March 9, 2017 N/A Commitment Change Evaluation for RSHx and Piping -
Frequency Change to Every 8th Refueling Outage January 9, 2015 ER-SU-5314 Generic Letter 89-13 Program Revision 2 P-SURR-338497 Change Existing RE Frequency from 7 years to 14 years for Charging Pump Intermediate Seal Coolers May 19, 2014 During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. However, for the scope of program program element, sufficient information was not available to determine whether it was consistent with the GALL-SLR Report AMP. The staff will consider issuing an RAI regarding the periodic replacement of the charging pump intermediate seal coolers to obtain the information necessary to verify whether this program element is consistent with the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the FSAR supplement description of the SLRA AMP for the Open-Cycle Cooling Water System program. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.12, Closed Treated Water Systems Summary of Information in the Application. The SLRA states that AMP B.2.1.12, Closed Treated Water Systems, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M21A, Closed Treated Water Systems. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements to the GALL-SLR Report AMP and will document its evaluation of Dominions bases in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominion personnel and reviewed documentation provided by them. The staff reviewed the following relevant documents:
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1315 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Closed Treated Water Systems Revision 1 CH-93.400 Closed Cooling Water Chemistry Program Revision 23 3002000590 EPRI Closed Cooling Water Chemistry Guideline Revision 2 During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. However, for the scope of program program element, sufficient information was not available to determine whether it was consistent with the GALL-SLR Report AMP. The staff will consider issuing an RAI regarding the periodic replacement of the charging pump intermediate seal coolers to obtain the information necessary to verify whether this program element is consistent with the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will consider issuing an RAI regarding corrosion product accumulation and erosion to obtain the information necessary to determine whether Dominions program can be adequate to manage the associated aging effects.
The staff also audited the FSAR supplement description of the SLRA AMP for the Closed Treated Water Systems program. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The SLRA states that AMP B.2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1316 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Revision 1 N/A Surry Power Station Units 1 and 2 Application for Subsequent License Renewal October 2018 VPAP-0809 NUREG-0612 Heavy Load Program Revision 10 MA-AA-101 Fleet Lifting and Material Handling Revision 23 0-MCM-1304-01 Turbine Polar and Fuel Handling Crane Maintenance Revision 14 0-MCM-1304-02 Inspection and Maintenance of Harnischfeger P&H 1.5 Ton Hoist Revision 5 0-MPM-1320-01 Monorail, Underhung, Base Mounted, Jib and Overhead Hoist Inspection Revision 11 ER-SU-AUG-101 Surry Augmented Inspection Program Revision 17 N/A Surry Operating Experience Report by Document 11/30/2018 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.14, Compressed Air Monitoring Summary of Information in the Application. The SLRA states that AMP B.2.1.14, Compressed Air Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M24, Compressed Air Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements to the GALL-SLR Report AMP in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1317 Subsequent License Renewal Project Aging Management Program Evaluation Report - Compressed Air Monitoring Revision 1 0-CSP-IA-001 Instrument Air Quality Test: Turbine Building Air Dryers Revision 9 0-CSP-IA-004 Instrument Air Quality Test: Low Level Air Dryers Revision 9 0-CSP-IA-005 Instrument Air Dew Point and Particulate Test Revision 11 0-CSP-IA-006 Instrument Air Hydrocarbon Test Revision 6 0-CSP-IA-007 Service Air Quality Test: Turbine Building Service Air Dryers Revision 0 1-CSP-IA-002 Instrument Air Quality Test: Containment Air Dryer Revision 6 2-CSP-IA-002 Instrument Air Quality Test: Containment Air Dryer Revision 7 ER-AA-AMP-101 Implementation of Activities Performed by License Renewal Aging Management Coordinators Revision 10 GL 88-14 Instrument Air Supply System Problems Affecting Safety-Related Equipment 08/08/1988 N/A Response to Generic Letter 88-18 02/21/1989 N/A Supplemental Response to Generic Letter 88-18 03/25/1993
During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Compressed Air Monitoring program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.15, Fire Protection Summary of Information in the Application. The SLRA states that the Fire Protection program is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M26, Fire Protection. To verify this claim of consistency, the staff audited the SLRA AMP.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1318 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Fire Protection Revision 1 N/A Surry Power Station Appendix R Report Revision 37 0-LPT-FP-012 0-LPT-FP-013 0-LPT-FP-014 0-LPT-FP-015 0-LPT-FP-016 Fire Barriers (Including Penetration Seals) [Inspections]
Revision 4 Revision 3 Revision 3 Revision 3 Revision 3 0-LPT-FP-022 Operability Test of Fuel Oil Pump Houses High Pressure CO2 System Revision 12 0-LPT-FP-027 Operability Test of Emergency Service Water Fuel Oil Storage Tank Room High Pressure CO2 System Revision 9 0-LSP-FP-036 Security Halon System Functional Test Revision 5 0-LSP-FP-039 LEOF [Local Emergency Operating Facility] Halon System Functional Test Revision 3
Document Title Revision / Date 1-LPT-FP-017 2-LPT-FP-017 Flow Test of Emergency Switchgear Room Halon System Revision 14 Revision 15 0-MPM-1910-10 Inspection (Functional Check) of Swinging Safety-Related Special Purpose Fire Doors Revision 11 0-MPM-1910-11 Inspection (Functional Check) of NSQ [Non-Safety-Related With Special Quality/Regulatory Requirements], Special Purpose Fire Doors, and Beyond Design Basis (BDB) Flood Doors Revision 13 0-OSP-FP-010 Daily Fire Door Inspection Revision 7 1-LSP-FP-007 2-LSP-FP-007 Inspection of Fire Retardant Coatings, Penetration Seals, Cable Trays, and Fire Stops Revision 4 Revision 5 1-LSP-FP-008 2-LSP-FP-008 Inspection of Containment Fire Retardant Coatings, Energy Shields, Cable Trays, Fire Stops, and RCP Oil Collection Systems Revision 9 Revision 10 CE-0087 Guideline for Monitoring of Structures, SPS [Surry Power Station]
Revision 7 CM-AA-FPA-100 Fire Protection/Appendix R (Fire Safe Shutdown) Program Revision 13 CM-AA-FPA-101 Control of Combustible and Flammable Materials Revision 8 CM-AA-FPA-102 Fire Protection and Fire Safe Shutdown Review and Preparation Process and Design Change Process Revision 8 ER-AA-101 System Engineering Walkdowns Revision 2 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the SLRA Fire Protection Program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.16, Fire Water System Summary of Information in the Application. The SLRA states that AMP B.2.1.16, Fire Water System, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-SLR Report AMP XI.M27, Fire Water System. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exceptions and enhancements associated with this AMP. The staff will document its review of the exceptions to the GALL-SLR Report AMP and the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1319 Subsequent License Renewal Project Aging Management Program Evaluation Review - Fire Water System Revision 3 ETE-SLR-2018-1320 Subsequent License Renewal Project Aging Management Program Evaluation Review - Outdoor and Large Atmospheric Metallic Storage Tanks Revision 1 SU-2014-2020 Evaluation of 2014 Inspection of 1-FP-TK-1A 08/25/2014 NA Surry Power Station Tank 1-FP-TK-1A Data Scan Tank Bottom Survey Report 02/14/2014 SU-2014-0081 Evaluation of 2014 Inspection of 1-FP-TK-1 10/30/2014 NA Surry Operating Experience Report by Document NA ER-AA-AMP-101 Implementation of Activities Performed by License Renewal Aging Management Coordinators Revision 10 NA Updated Final Safety Analysis Report, Section 9.10.2.2.2, Fire Pumps Revision 49 CM-AA-FPA-100 Fire Protection/Appendix R (Fire Safe Shutdown)
Program Revision 14 0-LPT-FP-025 Flow Test of Hose Station Valves Revision 5 0-LSP-FP-044 Operability Test for Fire Protection Valves Outside Protected Area Revision 8 0-OPT-FP-004 Fire Protection - Fire Main Flush Revision 14 0-OPT-FP-006 Flow Test of Fire Protection System Revision 7
Document Title Revision / Date 0-OPT-FP-007 Operability Test of Fire Protection Valves Inside the Protected Area Revision 6 1-LPT-FP-016 Flow Test of Cable Tunnel Sprinkler System Revision 7 1-LSP-FP-001 Station Service and Main Transformer Deluge Fire Protection Functional Test Revision 5 1-OSP-FP-003 Fire Protection Main Drain Valve Test Revision 10 WO-38204185348 Work Order: Fire Protection/Domestic Water Storage Tanks (FWST) Internal Inspection NA 38103801739 Preventive Maintenance: Clean/Inspect Strainer NA 38203874287 PM: Perform External Visual Inspection of Tank NA ETE-SU-2015-0004 License Renewal Commitment 6: Incorporate NFPA 25, Section 2-3.1.1 for Sprinklers 09/01/2015 WO-38103472994 WO-38103853063 Work Order Diver Inspection of FWST 1A 08/27/2018 WO-38103534909 WO-38103853368 Work Order Diver Inspection of FWST 1B 08/28/2018 0-VSP-A3 Annunciator Response Procedure - Diesel Fire PP
[pump] Auto Start Revision 7 0-VSP-L3 Annunciator Response Procedure - Mtr [motor] Fire Pump Running Revision 4 EE-AA-NDE-123 Dominion Written Practice for Certification of Visual Examination Personnel Revision 4 0-LSP-FP-008 Pre-Action and Wet Pipe Sprinkler Visual Inspection Revision 5 ETE-SU-2013-0044 Appendix R Engineering Evaluation: Adequacy of One Fire main Pump Supplying Flow to Turbine Building Sprinklers and 500 gpm Hose Station 12/03/2013 NA Surface Water Indications Operating Experience 02/28/2019 During the audit, the staff verified that, for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain
the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff will consider issuing RAIs to obtain the information necessary to determine whether Dominions SLRA Fire Water System program can be adequate to manage the associated aging effects.
The staff also audited the description of the SLRA Fire Water System program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the Fire Water System program. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.
SLRA AMP B.2.1.17, Outdoor and Large Atmospheric Metallic Tanks Summary of Information in the Application. The SLRA states that the Outdoor and Large Atmospheric Metallic Storage Tanks program is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-SLR Report AMP XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the exceptions and enhancements associated with this AMP. The staff will document its review of the exceptions to the GALL-SLR Report AMP and the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1320 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report-Outdoor and Large Atmospheric Metallic Storage Tanks Revision 1 N/A XI.M29 Enhancement Summary November 16, 2018 CM-AA-CTG-104 Condition Assessment of Internally Coated/Lined Tanks, Components, and Pipes Subject to Immersion Service Revision 2 ER-AA-BPM-101 Underground Piping and Tank Integrity Program Revision 12 1-NPT-CN-001 Inservice Inspection System Pressure Test of 1-CN-TK-1 (ECST) and Associated Components Revision 4 1-NPT-CS-001 Inservice Inspection System Pressure Test of 1-CS-TK-1 (RWST) and Associated Components Revision 3
Document Title Revision / Date 1-NPT-CS-004 Inservice Inspection System Pressure Test of the Unit 1 Refueling Water Chemical Addition Tank and Associated Components Revision 3 2-NPT-CN-001 Inservice Inspection System Pressure Test of 2-CN-TK-1 (ECST) and Associated Components Revision 4 2-NPT-CS-001 Inservice Inspection System Pressure Test of the RWST, 2-CS-TK-1, and Associated Components Revision 3 2-NPT-CS-004 Inservice Inspection System Pressure Test of the Unit 2 Refueling Water Chemical Addition Tank and Associated Flow Path Revision 3 ETE-SU-2011-0103 License Renewal Tank Inspection Plans for the Period of Extended Operation Revision 3 ET-MAT-03-0002 Coating of Condensate Tanks Revision 0 NUS-112 Fire Protection and Domestic Water Storage Tank July 15,1968 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program and monitoring and trending program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also verified Dominions claim that aspects of the preventive actions, parameters monitored or inspected, detection of aging effects, acceptance criteria, and corrective actions program elements not associated with the exceptions identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the SLRA Outdoor and Large Atmospheric Metallic Tanks program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.18, Fuel Oil Chemistry Summary of Information in the Application. The SLRA states that AMP B.2.1.18, Fuel Oil Chemistry, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-SLR Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exceptions and enhancements associated with this AMP. The staff will document its review of the exceptions to the GALL-SLR Report AMP and the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1321 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Fuel Oil chemistry Revision 1 CY-AA-AUX-310 Diesel Fuel Oil Sampling and Testing Revision 9 CY-AA-100 Conduct of Chemistry Revision 12 CH-32.110 Fuel Oil Sampling and Analysis Control Revision 18 0-LOG-SBNY-001 Service Building North Yard Logs Revision 107 0-LOG-SBIS-001R Service Building Inside Logs Revision 79 0-CSP-SEC-001 Security Diesel Fuel Oil Tank Chemistry Revision 4 0-CPT-FP-001 Diesel Driven Fire Pump Fuel Oil Tank, 1-FP-TK-4, Chemistry Revision 4 0-CSP-EG-002 Diesel Fuel Oil Tanks; 1-EE-TK-2A and 1-EE-TK-2B, Water and Bacteria Determination Revision 6 0-CSP-SW-001 Emergency Service Water Pump Diesel Fuel Oil Tank, 1-SW-TK-1, Water and Bacteria Determination Revision 3 11448-1.30-119A, Sh.
1 Power Unit Installation Revision 1 11448-1.30-119A, Sh.
2 Power Unit Installation Revision 1 CH-72.W01 Water and Sediment: Lube Oil and Fuel Oil Revision 3 N/A Technical Requirements Manual Revision 37 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, and corrective actions program element) of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also verified Dominions claim that aspects of the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria, program elements not associated with the exception identified in the SLRA during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.
In addition, the staff found that for the parameters monitored or inspected, program element, sufficient information was not available to determine whether it was consistent with the
corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing an RAI to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed ETE-SLR-2018-1321 and noted that the applicant follows ASTM D1796-83 to test for water and sediment in the diesel fuel oil.
The staff reviewed document ETE-SLR-2018-1321 and noted that the security diesel generator fuel oil tank has a solvent-based rust preventive film on the inside of the tank.
Staff reviewed drawings 11448-130-119A Sheet 1 and Sheet 2 and noted that the security diesel and EDG base tanks dont appear to be accessible for bottom thickness measurements, or internal visual inspections. The staff also reviewed the SLRA and noted that there are proposed measures to justify exceptions to several GALL-SLR elements related to bottom thickness measurements, and internal visual inspections of the tanks.
The staff reviewed CRs 003949, 517334, 526769, and 009031 and noted that when testing the fire protection diesel taking a suction from tank 1-FP-TK-4, the diesel experienced surging/overspeed issues, and that water and corrosion materials were detected in the tank.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff will consider issuing an RAI to obtain the information necessary to determine whether Dominions SLRA Fuel Oil Chemistry program can be adequate to manage the associated aging effects.
The staff also audited the description of the SLRA Fuel Oil Chemistry program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.19, Reactor Vessel Material Surveillance Summary of Information in the Application. The Subsequent License Renewal Application (SLRA) states that Aging Management Program (AMP) B.2.1.19 Reactor Vessel Material Surveillance, is an existing program with enhancements that are consistent with the program elements defined in the GALL-SLR Report AMP XI.M31 Reactor Vessel Material Surveillance.
To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the safety evaluation report (SER). During the audit, the staff reviewed the enhancements with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed the following relevant documents provided by Dominion.
Relevant Documents Reviewed Document Title Revision and/or Date ETE-SLR-2018-1322 Subsequent License Renewal Project Aging Management Program Evaluation Report - Reactor Vessel Material Surveillance - Surry Power Station Revision 2 ER-AA-RVI-101 Administrative Procedure - Reactor Vessel Integrity Program Revision 4 1-PT-4 Engineering Periodic Test Procedure - Reactor Vessel Exposure (for Surry Power Station, Unit 1)
Revision 7 2-PT-4 Engineering Periodic Test Procedure - Reactor Vessel Exposure (for Surry Power Station, Unit 2)
Revision 7 MCOE-LTR-17-26 Westinghouse Letter - Surry Units 1 and 2 Surveillance Capsule Withdrawal Schedule for SLR Revision 2 WCAP-18028-NP Extended Beltline Pressure Vessel Fluence Evaluations Applicable to Surry Units 1 and 2, April 2018 Revision 1 WCAP-18242-NP Surry Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity for Subsequent License Renewal Revision 2 BAW-1543 Supplement to the Master Integrated Reactor Vessel Surveillance Program - Supplement 7A Revision 4 During the audit, the staff verified that the following program elements of AMP B.2.1.19 are consistent with the corresponding elements of the GALL-SLR Report AMP: scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions.
During the audit the staff made the following observations:
The staff confirmed in the reactor vessel surveillance program basis document (ETE-SLR-2018-1322) that Dominion included enhancements in AMP B.2.1.19 and a commitment (Commitment 19) for implementing the enhancements. The enhancements include withdrawing at least one surveillance capsule from each unit during the subsequent license renewal (SLR) period, when the capsule is projected to have reached between one to two times the peak reactor pressure vessel fluence at the end of the SLR period. The staff noted that the capsules scheduled to be withdrawn during the SLR period are not the same as those scheduled to be withdrawn during the initial license renewal period.
The staff observed in WCAP-18242-NP that surveillance capsules specific for Surry Power Station (SPS), Units 1 and 2, as well as surveillance capsules from other plants are used for reactor pressure vessel material embrittlement calculations.
The staff observed in the figures in WCAP-18028-NP and WCAP-18242-NP that show the plan view of the surveillance capsule locations that surveillance capsules that were relocated were placed in the appropriate octant symmetry locations.
During the audit of the operating experience program element associated with the AMP, the staff independently searched the database specific to SPS, Units 1 and 2 to identify any previously unknown or recurring aging effects. Additionally, as the staff noted in the operating experience audit report, the staff identifies the following reactor vessel surveillance capsule reports relevant to the SPS, Units 1 and 2 operating experience.
SPS Unit 1 Surveillance Capsule Reports Capsule Title Date T
Surry Unit No. 1 Pressure Vessel Irradiation Capsule Program: Examination and Analysis of Capsule T June 24, 1975 W
Surry Unit No. 1 Nuclear Plant Reactor Pressure Vessel Surveillance Program: Examination and Analysis of Capsule W
March 30, 1979 V
WCAP-11415: Analysis of Capsule V from the Virginia Electric and Power Company Surry Unit 1 Reactor Vessel Radiation Surveillance Program February 1987 X
BAW-2324: Analysis of Capsule X - Virginia Power Surry Unit No. 1 - Reactor Vessel Material Surveillance Program April 1998 SPS Unit 2 Surveillance Capsule Reports Capsule Title Date X
Surry Unit No. 2 Pressure Vessel Irradiation Capsule Program:
Examination and Analysis of Capsule X September 2, 1975 W
Surry Unit No. 2 Nuclear Plant Reactor Pressure Vessel Surveillance Program: Examination and Analysis of Capsule W February 27, 1981 V
WCAP-11499: Analysis of Capsule V from the Virginia Electric and Power Company Surry Unit 2 Reactor Vessel Radiation Surveillance Program June 1987
SPS Unit 2 Surveillance Capsule Reports Capsule Title Date Y
WCAP-16001: Analysis of Capsule Y from Dominion Surry Unit 2 Reactor Vessel Radiation Surveillance Program February 2003 Sister Plant Surveillance Capsule Reports Capsule Title Date TMI1-E BAW-1439: Analysis of Capsule TMI1-E from Metropolitan Edison Company - Three Mile Island Nuclear Station - Unit 1 Reactor Vessel Materials Surveillance Program January 1977 TMI1-C BAW-1901: Analysis of Capsule TMI1-C - GPU Nuclear - Three Mile Island Nuclear Station - Unit 1 - Reactor Vessel Material Surveillance Program March 1986 PB1-R WCAP-9357: Analysis of Capsule R from the Wisconsin Electric Power Company Point Beach Nuclear Power Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program August 1978 PB1-S WCAP-8739: Analysis of Capsule S from the Wisconsin Electric Power Company Point Beach Nuclear Power Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program August 1976 PB1-T WCAP-10736: Analysis of Capsule T from the Wisconsin Electric Power Company Point Beach Nuclear Power Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program December 1984 PB1-V Point Beach Nuclear Plant Unit No. 1 Pressure Vessel Surveillance Program: Evaluation of Capsule V June 15, 1973 Master Integrated Reactor Vessel Surveillance Program Data Sources For Shift in Reference Temperature and Upper Shelf Energy Capsule Report Number Date TMI2-LG1 CR3-LG1 CR3-LG2 ANP-2650: Updated Results for Request for Additional Information Regarding Reactor Pressure Vessel Integrity July 2007 W1 ANP-2650: Updated Results for Request for Additional Information Regarding Reactor Pressure Vessel Integrity July 2007 BAW-2350P: Test Results of W1 Capsule April 1999 A5 BAW-2360P: Analysis of A5 Capsule June 1999 The staff also audited the UFSAR supplement summary description of AMP B.2.1.19 in SLRA Section A.1.19, Reactor Vessel Material Surveillance. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.20, One-Time Inspection Summary of Information in the Application. The SLRA states that AMP B.2.1.20, One-Time Inspection, is a new condition monitoring program that will be consistent with the program elements in GALL-SLR Report AMP XI.M32, One-Time Inspection. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1323 Subsequent License Renewal Project Aging Management Program Evaluation Report - One-Time Inspection Revision 1 November 2018
Document Title Revision / Date ETE-SLR-2018-1323 Subsequent License Renewal Project Aging Management Program Evaluation Report - One-Time Inspection Revision 2 February 2019 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA One-Time Inspection AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed Section 3.1.2.2.2 of the SLRA and noted that the applicant plans on using the One-Time Inspection program to address potential weld degradation in the SG shell, as noted in Information Notice 90-04, Cracking of the Upper Shell-to-Transition Cone Girth Welds in Steam Generators.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP for One-Time Inspection provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.21, Selective Leaching Summary of Information in the Application. The SLRA states that AMP B.2.1.21, Selective Leaching, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M33, Selective Leaching. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1324 Subsequent License Renewal Project Aging Management Program Evaluation Report - Selective Leaching Revision 3 ER-AA-AMP-101 Implementation of Activities Performed by License Renewal Aging Management Coordinators Revision 10 ER-AA-NDE-123 Dominion Written Practice for Certification of Visual Examination Personnel Revision 4
During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Selective Leaching program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.22, ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The SLRA states that AMP B.2.1.22, ASME Code Class 1 Small-Bore Piping, is a new program with an exception, that will be consistent with the program elements in GALL-SLR Report AMP XI.M35, ASME Code Class 1 Small-Bore Piping.
To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed the program elements described in the applicants basis documents. During the audit the staff reviewed exceptions associated with this AMP. The staff will document its review of the exceptions to the GALL-SLR Report AMP in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1325 Subsequent License Renewal Project Aging Management Program Evaluation Report ASME Code Class 1 Small-Bore Piping Surry Power Station Revision 1 November 2018 ETE-SLR-2018-1325 ASME Code Class 1 Small-Bore Piping Determination of Populations Revision 1 ETE-SLR-2018-1325 ASME Code Class 1 Small-Bore Piping RCP Seal Injection Thermal Barrier Flange Welds Revision 1 ER-AA-ISI-100 Dominion Inservice Inspection Program Revision 10 ER-SU-AUG-101 Surry Augmented Inspection Program Revision 17 ER-AANDE-140 Processing of Dominion NDE Data Revision 5 December 2011 ID_Rpt_M35 Surry Power Station SLR Component List for AMP ASME Code Class 1 Small-Bore Piping
During the audit, the staff verified Dominions claim that aspects of the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements not associated with the exceptions identified in the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.23, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The SLRA states that AMP B.2.1.23, External Surfaces Monitoring of Mechanical Components, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements to the GALL-SLR Report AMP in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ER-AA-101 System Engineering Walkdowns Revision 2 ETE-SLR-2018-1326 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - External Surfaces Monitoring of Mechanical Components Revision 3 Jan. 2019 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA External Surfaces Monitoring of Mechanical Components AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any conditions or operating experience that would indicate that the External Surfaces Monitoring of Mechanical Components AMP may not
be adequate to manage the associated aging effects. The staff will evaluate the identified plant-specific operating experience in the SER. Based on its review, the staff will consider issuing an RAI to obtain the information about ongoing, periodic, wall-thickness measurements discussed in CR-565668, for monitoring external corrosion on component cooling water piping.
The staff also audited the description of the SLRA AMP for External Surfaces Monitoring of Mechanical Components provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.24, Flux Thimble Tube Inspection Summary of Information in the Application. The SLRA states that AMP B.2.1.24, Flux Thimble Tube Inspection is an existing program that, when subject to an enhancement, will be consistent with the program element criteria defined in GALL AMP XI.M37, Flux Thimble Tube Inspection.
To verify this claim of consistency, the staff audited this AMP. At the time of the audit, Dominion had not yet fully developed the documents necessary to implement this new program, and the staffs audit only addressed the following aspects of the AMP: (a) existing program element criteria of the AMP claimed by the applicant as being consistent with the corresponding program element criteria in GALL AMP XI.M37, (b) the programmatic enhancement associated with the detection of aging effects and acceptance criteria program elements of the AMP, including those aspects of the enhancement that the staff determined were in need of additional audit discussions or clarifications with the staff, and (c) past operating experience events that may be applicable to the flux thimble tubes or AMP, but were not summarized or discussed in the operating experience program element section of the applicants AMP.
The staff will document its review of the AMP enhancement and relevant site-specific or generic operating experience related to flux thimble tube degradation in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed document provided by Dominion. The staff reviewed the following documents.
Relevant Documents Reviewed Document Title Revision /
Date Engineering Technical Evaluation No.
ETE-SLR-2018-1327 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Flux Thimble Tube Inspection Revision 0 SPS Corrective Action (CA) Report No.
199817 CA to Operations Documenting Unit 2 Reactor Vessel Foreign Objection Inspections 04/30/2011 NRC Bulletin 88-09 Thimble Tube Thinning in Westinghouse Reactors 07/26/1988 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, acceptance criteria, and corrective actions program element(s) of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that additional clarifications were necessary for the staffs review of the programmatic enhancement associated with the AMP. The staff will consider issuing an RAI to verify that, when the enhancement is implemented, these program elements will be consistent with the corresponding program elements in GALL-SLR AMP XI.M37.
During the audit, the staff made the following observations:
During its review of the programmatic enhancement associated with the AMP, the staff noted that the programmatic enhancement is associated with the detection of aging effects and acceptance criteria program elements of the AMP. The staff observed that the enhancement indicates a plant-specific procedure will be developed for performing future eddy current inspections of the flux thimble tubes rather than continuing to use the current, generic procedure for the tube inspections. The staff also observed that, for this aspect of the enhancement, the applicant did not identify whether the site-specific procedure would define the inspection frequency that will be used to implement the component-specific inspections, or the criteria that would be used to re-establish the inspection frequency if the frequency for performing inspections was to change in the future. For these aspects, the staff noted that the detection of aging effects element in GALL-SLR AMP XI.M37 would call for the procedure to address the frequency that will be used to perform re-inspections of the thimble tubes.
The staff noted that the current program calls for the applicant to perform inspections of the thimble tubes once every other refueling outage. However, based on discussions with the applicant during the staffs audit teleconference with the applicant on February 6, 2019, the staff noted that the site-specific procedure (when developed by the applicant in accordance with the programmatic enhancement and SLRA UFSAR Commitment No. 24), may permit the applicant to re-baseline the inspection frequency of the AMP based on the results of the component-specific inspections. The staff noted that the inclusion of such criteria into the procedure would be consistent with the criteria for establishing flux thimble tube re-inspection frequencies, as specified in NRC Bulletin 88-09 and make the procedure consistent with the criteria in the Bulletin. This matter is resolved without the need for issuing any RAI on the matter.
The staff noted that, regarding the programmatic enhancement of the site-specific procedure, the AMP states that the procedure will include the acceptance criterion, with the basis, for loss of material for the inner flux thimble tube and identify remediating actions to be implemented if the acceptance criterion is exceeded. The staff observed that the current plant design utilizes a double-tubed flux thimble tube design, where inner tube is identified as the portion the tube design that is part of the reactor coolant pressure boundary, but where the outer tube is identified as being the tube in the design that is most susceptible to loss of material degradation by a wear mechanism. The staff noted that further clarifications are warranted on these matters because the basis document for the AMP does not define which of the tubes and tube surfaces in the design are being inspected by the current program, and whether this may change for the site-specific program that will be implemented during the subsequent period of extended operation. The staff noted that this could be particularly relevant if the current program performs the eddy current examinations from the outside surface of the outer tube in the design, but the acceptance criteria will be developed for evaluating potential degradation in the inner tube of the tube design; if this is the case, cross correlations would need to be developed on how the outer tube inspections would be used to evaluate degradation postulated to occur in the inner tubes of the double-tubed thimble tube design.
During the staffs audit teleconference with the applicant on February 6, 2019, the applicant explained that the eddy current examinations performed on the thimble tubes are actually performed on inside surfaces of the inner tubes. The staff noted that this clarifies that the inspections of the double-tubed thimble tube design are being performed on the tubes that serve a reactor coolant pressure boundary function. This matter is resolved without the need for issuing an RAI on the matter.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff identified one operating experience (OpE) event associated with loose parts from thimble tube assemblies in Unit 2 that was not summarized in the operating experience program element discussion of the AMP. The staff observed the OpE event is cited in Unit 2 Correct Action Report No. CA199817, dated April 30, 2011. During an audit teleconference held with the applicant on February 6, 2018, the applicant explained that the source of loose parts detected on the lower core support plate was an attachment associated maintaining the position of tubes in the thimble tube assembly. The applicant explained that the loose parts discussed in the CA report were not the result of a failed thimble tube. The applicant stated its 10 CFR Part 50, Appendix B corrective actions addressed the loose parts detected on the lower core support plate. Since the applicant has addressed the operating experience through implementation of its 10 CFR Part 50, Appendix B Quality Assurance Program, and since the staff has verified that the referenced operating experience is not associated with the failure of a thimble tube, the staff considers this OpE matter to be resolved The staff also audited the description of the Flux Thimble Tube Inspection Program provided in the FSAR Supplement Section A1.24. The staff verified this description is consistent with the description provided in GALL-SLR Table XI.01 for GALL-SLR AMP XI.M37, Flux Thimble Tube Inspection.
SLRA AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The SLRA states that AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1328 Surry Subsequent License Renewal Project - Aging Management Program Evaluation - Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Revision 1 ER-AA-AMP-101 Implementation of Activities Performed by License Renewal Aging Management Coordinators Revision 10 WM-AA-100 Work Management Revision 31 0-NSP-Pl-004 Inspection of Roof Drains, Yard Drains and Roofs Revision 0 ER-AA-NDE-VT-601 Nondestructive Examination Procedure Revision 4 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the parameters monitored or inspected and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP.
The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.26, Lubricating Oil Analysis Summary of Information in the Application. The SLRA states that AMP B.2.1.26, Lubricating Oil Analysis, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M39, Lubricating Oil Analysis. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1329 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Lubricating Oil Analysis Revision 1 0-NSP-LO-001 Sampling EHC and Lube Oil Systems Revision 2 ER-AA-101 System Engineering Walkdowns Revision 2 VPAP-0812 Station Lubrication Program Revision 18 ETE-SU-2015-1020 Technical Basis for Equipment Oil Sampling Frequency Revision 0 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing an RAI to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit the staff made the following observation:
The staff reviewed ETE-SU-2015-1020 as cited in the Relevant Documents Reviewed table and noted obtaining oil samples from condensate motors, high pressure heater drain motors, low pressure heater drain motors, circulating water motors, component cooling pumps/motors, bearing cooling pumps/motors while the equipment is operating may place undue risk to the plant and personnel safety.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Lubricating Oil Analysis provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.27, Buried and Underground Piping and Tanks Summary of Information in the Application. The SLRA states that AMP B.2.1.27, Buried and Underground Piping and Tanks, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1330 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Buried and Underground Piping and Tanks Revision 0 ETE-SU-2017-0009 Life Cycle Management Plan Surry Power Station Underground Piping and Tank Integrity Program Revision 12 ER-AA-BPM-101 Underground Piping and Tank Integrity Program Revision 12 ETE-NAF-2011-0045 Surry Power Station Buried Piping Risk Impact Assessment Revision 0 0-EPM-2308-01 Inspection of Emergency Diesel Generator Fuel Oil Piping Cathodic Protection Revision 3 0-EPM-2308-02 Emergency Diesel Generator Fuel Oil Piping Cathodic Protection Rectifier Inspection and Adjustment Revision 5 DQR-PGM-PGM-AA-CTG Dominion Engineering Support Fleet Lead and Site Owner Revision 4 NUS-130 Specification for Excavation and Placement of Compacted Fill for Surry Power Station Virginia Electric and Power Company 01/04/1968 ETE-SU-2014-0080 Assessment for Additional Cathodic Protection at Surry Power Station Revision 0 11448-FV-36A Underground Fuel Oil Storage Tanks MK Nos. EE-TK-2A & 2B Revision 4 NUS-115 Specification for Precast Concrete Water Pipe for Surry Power Station 02/19/1968 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, parameters monitored or inspected, monitoring and trending, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the preventive actions, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed Condition Report (CR) 006624 and noted that buried auxiliary feedwater piping was found to be leaking in 2004 and that the cause of the degradation was lack of a protective wrap on the affected line.
The staff reviewed CR 011232 and noted that: (a) no preventive maintenance activities were required for the passive cathodic protection on the emergency diesel generator (EDG) fuel oil lines because the lines were designed to last many years; and (b) a shop coating was applied to the EDG fuel oil lines to reduce holidays.
The staff reviewed CR 105973 and noted that: (a) during inspection of buried piping, several pipelines associated with the containment spray and chemical volume and control systems indicated coating failure where the felt wrap had separated from the coal tar coating; and (b) the exposed bare metal surfaces showed no indication of corrosion.
The staff reviewed CR 114414 and noted that during excavation activities associated with a work order, a buried fire protection leak was identified.
The staff reviewed CR 386494 and noted that during an excavation to support guided wave examinations, areas of pitting were identified on the exterior surfaces of the pipe. The lowest remaining wall thickness was 0.122 inches compared to a nominal pipe thickness of 0.245 inches.
The staff reviewed CR 441171 and noted that a 1-inch diameter through wall hole was identified on a buried fire protection line.
The staff reviewed CR 480972 and noted that: (a) a 3 to 4 inch circumferential crack was identified on a 10-inch buried stainless steel condensate supply line; and (b) the damage appeared to be manmade and not corrosion related.
The staff reviewed CR 497540 and noted that two pin hole leaks were identified on a buried condensate line.
The staff reviewed CR 1068384 and noted that: (a) a few areas of missing coating were found on buried stainless steel containment spray piping; and (b) soil testing indicates that the subject piping resides in a mildly corrosive environment.
The staff reviewed CA 126782 and noted that: (a) use of cathodic protection at Surry for buried piping and tanks is minimal by comparison to the industry as Surry relies on quality backfill and coating systems; and (b) operating experience documents corrosion damage and failures resulting from damaged or poorly applied coatings.
The staff reviewed ETE-SLR-2018-1330 and noted that: (a) buried stainless steel piping in the containment spray, residual heat removal, chemical and volume control, and safety injection systems may be externally coated or wrapped; (b) buried stainless steel piping in the fuel oil system is not externally coated; (c) the approximate length of buried stainless steel piping is 1,416 feet; (d) the approximately length of buried concrete piping is 1,000 feet; (e) buried steel piping in the condensate, fuel oil, service water, chilled water, and ventilation systems may be coated with tar pitch with felt wrap, tape-wrap, or coal tar epoxy; (f) Preventive Action Category D has been selected for buried steel piping; (g) buried concrete piping does not have external coating; (h) underground steel and copper alloy piping may be wrapped or coated; (i) the chloride index value for each of the 48 soil samples from 32 locations was 0; therefore, stainless steel piping is not required to be coated; (j) buried fire protection piping has an external bituminous coating; (k) there has been no documentation of carbonate/bicarbonate soil environment conditions provided in previous soil sampling surveys; (l) the fire protection system was designed in accordance with applicable NFPA standards; and (m) regarding coating inspections, an individual with EPRI Comprehensive Coating Training or NACE Nuclear Power Plant Coating Training will evaluate whether the observed coating condition is acceptable.
The staff reviewed ETE-SU-2017-0009 and noted original plant specifications required that buried plant piping be coated with a coal tar pitch/felt wrap system.
The staff reviewed ETE-SU-2014-0080 and noted that (a) for buried stainless steel piping, there have been sporadic cases where poor coating adhesion or existing coating damage was identified and cases where certain systems were essentially uncoated; (b) for buried steel piping, there have been sporadic cases where poor coating adhesion or existing coating damage has been identified; (c) soil resistivity values ranged from 3,500 to 100,000 ohm-cm; (d) soil pH ranged from 5.67 to 11.05; (d) water content was greater than 20 percent for 33 out of 47 soil samples; (f) soil redox potentials ranged from -14 to 326 millivolts; and (g) soil sulfides ranged from zero to high.
The staff reviewed 11448-FV-36A and noted that the underground fuel oil storage tanks are coated externally with poxitar or approved equal.
The staff reviewed NUS-115 and noted that precast concrete water pipe will conform to American Water Works Association C302, Standard for Reinforced Concrete Pressure Pipe, Noncylinder Type.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Buried and Underground Piping and Tanks program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the Buried and Underground Piping and Tanks program. The staff will consider issuing RAIs to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
SLRA AMP B.2.1.28, Internal Coatings/Linings For In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Summary of Information in the Application. The SLRA states that AMP B.2.1.28, Internal Coatings/Linings For In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1331 Surry Subsequent License Renewal Project - Aging Management Program Evaluation - Internal Coatings/Linings For In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Revision 1 CM-AA-CTG-104 Condition Assessment of Internally Coated/Lined Tanks, Components, and Pipes Subject to Immersion Service Revision 2 ER-AA-AMP-101 Implementation of Activities Performed by License Renewal Aging Management Coordinators Revision 10 VPAP-1002 Quality Control (QC) Inspector Certification Program Revision 12 ER-AA-NDE-ET-500 Examination for the Detection and Sizing of Pitting, Corrosion, and Wall Loss Using Low Frequency Electromagnetic Techniques (LFET)
Revision 1 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the preventive actions, parameters monitored or inspected, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the scope of program, detection of aging effects, monitoring and trending, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed Condition Report (CR) 003120 and noted that the 96-inch diameter inlet circulating water piping exhibited numerous holidays and coating failures.
The staff reviewed CR 316728 and noted that while performing UT/video inspection of the fire protection and domestic water storage tanks, it was noted that there is blistering of the coating on the bottom and walls of the tank.
The staff reviewed CR 325572 and noted that: (a) for the fire protection and domestic water storage tanks, the bottom coating of the tanks are blistered but intact and the inside walls have some coating failures; and (b) for the emergency condensate storage tanks, there is little evidence of corrosion and the clarity of the water in both tanks is affected by the presence of biological growth.
The staff reviewed CR 403620 and noted that during removal of a service water motor operated valve from the system to replace an adjacent expansion joint, it was noted that the coating on the inner diameter of the flange was not intact, which led to corrosion due to service water being in direct contact with carbon steel.
The staff reviewed CM-AA-CTG-104 and noted that: (a) the procedure outlines the methods to monitor and assess the condition of coatings and liners on tank interiors, service water and circulating water pipe interiors, and other submerged components; (b) service water tanks are not included within the scope of the program; (c) tanks with an internal environment of closed-cycle cooling water are not included within the scope of the program; (d) a PM will not be generated or augmented to inspect fire protection piping in accordance with CM-AA-CTG-104; and (e) the pressurizer relief tank is internally coated with a polymeric material.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Internal Coatings/Linings For In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.29, ASME Section XI, Subsection IWE Summary of Information in the Application. The SLRA states that AMP B.2.1.29, ASME Section XI, Subsection IWE, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S1, ASME Section XI, Subsection IWE. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision/Date ETE-SLR-2018-1334 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - ASME Section XI, Subsection IWE Revision 1 ER-AA-CII-10 ASME Section XI Containment Inservice Inspection Program
[CISI] Program Revision 2 ER-AA-CII-102 ASME Section XI CISI (Metal/IWE) Program Fleet Implementation Requirements Revision 3 ER-AA-NDE-VT-605 IWE Visual Examination Procedure Revision 2 ER-AA-RRM-100 ASME Section XI Repair/Replacement Program Fleet Implementation Requirements Revision 6 ETE-CEP-2011-0010 ISI Program - CISI LR AMP Revision 1 and markup SPS-PLAN-000 01/02-CISI BASIS-IWE/IWL-INT3 Surry Unit 1 and Unit 2 Containment IWE Inservice Inspection Basis Document - IWE/IWL-INT3 Revision 0 SPS-PLAN-000 01/02-IWE-INT3 Surry Unit 1 and Unit 2 Containment IWE Inservice Inspection Plan - Third Ten-Year Containment Inspection Interval Revision 0 MS-AA-WHS-131 Storage and Handling - Administrative Procedure Revision 8 and markup Procedure GMP-M-150 Fabrication and Installation of Hangers Supports and Structures, Surry Power Station Revision 15 and markup N/A Surry SLR Component List for AMP ASME Section XI, Subsection IWE N/A Drawing 11448-FV-6A Fuel Transfer Tube Enclosure Revision 6 Drawing 11448-FV-I D Reactor Containment Liner Bottom Test Members Arrangement Revision 3 Drawing 11548-FV-I K Reactor Containment Liner Bottom Test Members Arrangement Revision 1 ET 00-0286 Containment Liner to Floor Joint Interface Inspection Report and Evaluation, Surry Power Station, Units 1 and 2 Revision 0 11/30/2000 CR 582361 NRC Violation for Failure to Conduct Augmented Visual Examination - Containment Concrete Floor to Liner Interface 1/1/2015 None Surry Operating Experience Report by Document (page 15 of 17): IN 2014-07 Degradation of Leak Chase Channel Systems for Floor Welds of Metal Containment Shell and Concrete Metallic Liner 10/19/2018
During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, monitoring and trending and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the parameters monitored or inspected, detection of aging effects and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider using the voluntary SLRA supplement information committed to by Dominion during the audit or issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP ASME Section XI, Subsection IWE provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP. The staff will consider using the voluntary SLRA supplement information committed to by Dominion during the audit or issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
SLRA AMP B.2.1.30, ASME Section XI, Subsection IWL Summary of Information in the Application. The SLRA states that AMP B.2.1.30, ASME Section XI, Subsection IWL, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S2, ASME Section XI, Subsection IWL. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1335 Subsequent License Renewal Project Aging Management Program Evaluation Report Revision 0 ER-AA-CII-10 ASME Section XI CISI Program Revision 2 ER-AA-CII-101 ASME Section XI CISI_IWL_Prog Fleet Implementation Requirements (and markup)
Revision 3 ER-AA-NDE-VT-606 IWL Visual Examination Procedure (and markup)
Revision 1
Document Title Revision / Date SU-PLAN-000-38-01-02 CISI Basis IWE-IWL-INT3 Revision 0 WO 38079565601 Building and Structures Monitoring Report 08/28/2012 SPS UFSAR Surry Power Station Updated Final Safety Analysis Report (UFSAR)
Revision 49 WM-AA-100 Work Management Revision 31 OE3_CR488760 Exposed Reinforcement 09/20/2012 OE1_CR001881_CR00 3924 Unit 2 Containment exterior concrete anomalies 09/27/2006 OE2_CR438611_CR43 8612 Unit 1 Containment concrete repairs not performed 08/19/2011 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the acceptance criteria and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether this/these program elements is/are consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed OE3_CR488760, OE1_CR001881_CR003924 and OE2_CR438611_CR438612, and noted that these describe anomalies in the exterior of concrete containment and/or concrete containment repairs. The staff plans to conduct an on-site audit to verify consistency of acceptance criteria, and corrective actions program elements of AMP B.2.1.30, ASME Section XI, Subsection IWL, and to determine whether additional information is needed.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff will consider issuing RAIs to obtain the information necessary to determine whether Dominions SLRA ASME Section XI, Subsection IWL program can be adequate to manage the associated aging effects.
The staff also audited the description of the SLRA ASME Section XI, Subsection IWL program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report/SRP-SLR.
SLRA AMP B.2.1.31 ASME Section XI, Subsection IWF Summary of Information in the Application. The SLRA states that AMP B.2.1.31, ASME Section XI, Subsection IWF, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S3, ASME Section XI, Subsection IWF. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1336 (CM-AA-ETE-101)
B.2.1.31 ASME Section XI, Subsection IWF (AMP 10 Element Evaluation)
Revision 1 MS-AA-WHS-131 Storage and Handling (Markup)
Revision 8 SU-PLAN-000-38 ISI-INT5 (RM-AA-101, 4)
VAPCO -Dominion, Surry Power Station Unit 1, Inservice Inspection Plan for Components and Components Supports -
Fifth 10-year Inservice Inspection Interval (Markup)
Revision 3 SU-PLAN-000-38 ISI-INT5 (RM-AA-101, 4)
VAPCO -Dominion, Surry Power Station Unit 2, Inservice Inspection Plan for Components and Components Supports -
Fifth 10-year Inservice Inspection Interval (Markup)
Revision 4 SU-PROC-000-GMP-M-150 Fabrication and Installation of Hangers, Supports, and Structures, Units 1 and 2 (Markup)
Revision 15 OE1_CR524106 Corrosion on Steel Angle (ASME Class 3 pipe Support)
August 26, 2013 OE2_CR548863 Degraded Pump Support (Unit 2)
May 14, 2014 OE3_CR547325 Loose Bolts on Pipe Clamp (Unit 2)
May 01, 2014 OE4_PIR1005185 Effectiveness Review (Self Assessment results Measurement Review, PI-AA-100-1004, Attachment 4)
December 10, 2015 OE5_CR1038564_CA3 033717 Admin Control Oversight (North Anna Power Station)
May 26, 2017 OE6_CR1076642_CA3 065495 Oversight Review (Units 1 and 2)
August 28, 2017 OE7_CR1065943_CA3 062203_CA3062601 AMP Effectiveness review (Units 1 and 2)
April 20, 2017
Document Title Revision / Date N/A OE Summary CR Listings (Surry Operating Experience Report by Document)
November 2, 2018 Docket No. 50-280 License No. DPR-82 VAPCO (Dominion), Surry Power Station Unit 1, Inservice Inspection Owners Activity Report (OAR-1), RFOs S1R21 through S1R27 February 22, 2008 -
February 6, 2017 Docket No. 50-280 License No. DPR-37 VAPCO (Dominion), Surry Power Station Unit 2, Inservice Inspection Owners Activity Report (OAR-1), RFOs S2R21 through S2R27 August 12, 2008 -
August 29, 2017 ID_Rpt_S03 Surry Power Station SLR Component List for AMP ASME Section XI, Subsection IWF N/A N/A ASME Boiler & Pressure Vessel Code,Section XI, Rules for Inspection of Nuclear Power Plant Components, 2004 Edition July 1, 2004 NUS-3007 Specification for Installation of Hilti Kwik Bolt II and Hilti Kwik Bolt 3 Anchor Bolts Revision 2 1-MCM-1150-01 Unit One Reactor Disassembly and Reassembly - Mechanical Corrective Maintenance Revision 37 CEM-0142 Sensitivity Evaluation of the Structural Adequacy of the Reactor Vessel Sliding Foot Assemblies for the Loss of Multiple Cap Screws, SPS Unit 1 - Addendum
Title:
Evaluation of Revised LOCA Loads for Surry Unit 1 and 2 RPV Sliding Foot Supports Revision 1 ETE-SU-2015-0006 (CM-AA-ETE-101, )
RV Support Sliding Foot Assembly Cap Screws Evaluation for Elimination Revision 0 In addition, the staff found that for the scope of program, parameters monitored or inspected, monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP. Specific areas of concern are:
Inclusion of the RPV ASME Code Class 1 supports (including the neutron shield tank
[NST]) and associated sliding foot assembly components in the scope of program program element.
Omissions of aging management of stainless steel sliding foot assembly components for IGSC cracking from parameters monitored or inspected program element and AMR items.
Inclusion of loss of material for wetted NST areas in the monitoring and trending program element.
During the audit the staff made the following observations:
The staff reviewed CEM-0142 and ETE-SU-2015-0006 and noted irradiation is an additional aging effect (in addition to aging effects identified and monitored by SLRA AMP B.2.1.31, ASME Section XI, Subsection IWF). Impact of irradiation on RPV sliding shoe assemblies and NST needs to be evaluated.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff will consider issuing an RAI regarding SPS response to IN 2010-01, Pipe Support Anchors Installed Improperly, to obtain the information necessary to determine whether Dominions SLRA AMP ASME Section XI, Subsection IWF can be adequate to manage the associated aging effects.
The staff also audited the description of the SLRA AMP ASME Section XI, Subsection IWF provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.32, 10 CFR Part 50, Appendix J Summary of Information in the Application. The SLRA states that AMP B.2.1.32, 10 CFR Part 50, Appendix J, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.S4, 10 CFR Part 50, Appendix J. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1337 Subsequent License Renewal Project, Aging Management Program (AMP), 10 CFR Part 50, Appendix J, Surry Power Station (SPS)
Revision 1 SPS UFSAR Chapter 1, Introduction and Summary; Chapter 5, Containment System; Chapter 15, Structures and Construction Revision 49 SPS UFSAR Section 5.5, Containment Tests and Inspections Revision 50.01 0-NSPT-CT-100 (U1 and U2)
Engineering Surveillance Procedure: Containment Leak Testing Controlling Document Revision 2
Document Title Revision / Date 1-NPT-CT-101 (U1) 2-NPT-CT-101 (U2)
Engineering Periodic Test Procedure: Reactor Containment Building Integrated Leak Rate Test (Type A Containment Test)
Revision 6, U1 Revision 7, U2 1-OPT-CT-201 (U1) 2-OPT-CT-201 (U2)
Operations Periodic Test Procedure: Containment Isolation Valve, Local Leak Rate Testing (Type C Containment Testing)
Revision 25, U1 Revision 22, U2 1-OPT-CT-202 (U1) 2-OPT-CT-202 (U2)
Operations Periodic Test Procedure: Fuel Transfer Tube Flange Local Leakage Revision 7, U1 and U2 1-OPT-CT-207 (U1) 2-OPT-CT-207 (U2)
Operations Periodic Test Procedure: Electrical Penetration Type B, Local leak Rate Test (Amphenol and Older Conax Penetrations)
Revision 10, U1 Revision 9, U2 1-OPT-CT-208 (U1) 2-OPT-CT-208 (U2)
Operations Periodic Test Procedure: Electrical Penetration Type B, Local Leak Rate Test (Conax Penetrations)
Revision 10, U1 Revision 9, U2 1-OPT-CT-209 (U1) 2-OPT-CT-209 (U2)
Operations Periodic Test Procedure: Westinghouse Electrical Penetration Type B, Local Leak Rate Test Revision 10, U1 Revision 9, U2 1-OPT-CT-301 (U1) 2-OPT-CT-301 (U2)
Operations Periodic Test Procedure: Personnel Airlock Pressure Test Revision 7, U1 Revision 8, U2 1-OPT-CT-302 (U1) 2-OPT-CT-302 (U2)
Operations Periodic Test Procedure: Equipment Hatch and Emergency Personnel Escape Airlock Leakage Test Revision 8, U1 Revision 9, U2 1-OPT-CT-303 (U1) 2-OPT-CT-303 (U2)
Operations Periodic Test Procedure: Personnel Airlock Leakage Test (Door Seal Test)
Revision 12, U1 and U2 1-OPT-CT-304 (U1) 2-OPT-CT-304 (U2)
Operations Periodic Test Procedure: Emergency Personnel Escape Airlock Leakage Test (Door Seal Test)
Revision 8, U1 and U2 1-OPT-CT-305 (U1) 2-OPT-CT-305 (U2)
Operations Periodic Test Procedure: Containment Purge Leakage Test Revision 10, U1 and U2 2-NPT-CT-101 Engineering Periodic Test and Surveillance Scheduling Sheet: Unit 2, Reactor Containment Building Integrated Leak Rate Test (Type A Containment Testing)
December 15, 2015 1-NPT-CT-101 Engineering Periodic Test and Surveillance Scheduling Sheet: Unit 1, Reactor Containment Building Integrated Leak Rate Test (Type A Containment Testing)
March 6, 2006 NRC Letter to VEPCO (U2)
Technical Specification (TS) Amendment 282 (extension of Type A test to 15 years and Type C tests to 75 months)
July 3, 2014 NRC Letter to VEPCO (U1 and U2)
TS Amendment 72 and 73 (requirements for implementation of TMI-2 Lessons Learned Category A items)
September 29, 1981
Document Title Revision / Date VEPCO Letter to NRC (U1 and U2)
LAR to change the referenced implementation document in RG 1.163 for 10 CFR Part 50, Appendix J testing to NEI 94-01 Rev 3-A August 12, 2013 SPS TS Section 3.8, Containment January 22, 1993 SPS TS Section 4.4, Containment Tests July 3, 2014 NRC Regulatory Guide (RG) 1.163 (ML003740058)
Performance-Based Containment Leak-Rate Testing Program September 1995 NEI 94-01 (ML13192A394)
Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J Revision 3-A ANSI/ANS 56.8 Containment System Leakage Testing Requirements 2002 11448-FV-1D Reactor Containment Liner Bottom Test Members Arrangement Revision 2 April 4, 1969 11548-FV-1K Reactor Containment Liner Bottom Test Members Arrangement (Original Issue)
Revision 1 April 17, 1969 WO38103767594 CR1052941 (scheduled completion October 22, 2019)
January 3, 2019 IN 2014-04 (ML13330B698)
Potential for Teflon Material Degradation in Containment Penetrations, Mechanical Seals, and Other Components March 26, 2014 IN 2010-12 (ML100640449)
Containment Liner Corrosion June 18, 2010 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding element(s) of the GALL-SLR Report AMP.
During the audit, the staff made the following observations:
The staff reviewed ETE-SLR-2018-1337 Attachment 1 and verified that the effects of aging for all of UFSAR Table 5.2-1 and Table 5.2-2 listed systems containment penetration configuration components excluded from 10 CFR Part 50 Appendix J testing are managed for SLRA Section B.2.1.32 through SLRA Sections B.2.1.2, B.2.1.11, B.2.1.12, B.2.1.20, B.2.1.23, B.2.1.29, B.2.1.30, and the visual inspection aspects of B.2.1.32. The aforementioned SLRA AMPs correspond to GALL-SLR Report AMPs XI.M2 (Water Chemistry), XI.M20 (Open-Cycle Cooling Water System), XI.M21A (Closed Treated Water Systems), XI.M32 (One-Time Inspection), XI.M36 (External Surfaces Monitoring of Mechanical Components), and XI.S1 (ASME Section XI, Subsection IWE), and XI.S2 (ASME Section XI, Subsection IWL) that have frequencies of inspections adequate to detect, trend the effects of aging and take corrective actions
when needed. The staffs individual AMR line item audit reviews of pressure boundary components based on listings in SLRAs Table 2 system sections and associated Table 1 references for components excluded from the 10 CFR Part 50, Appendix J LLRTs, are documented in the appropriate In Office Audit Report sections The staff reviewed 11448-FV-1D and 11548-FV-1K and verified that the floor the leak chase channels are embedded in concrete and have no access boxes of the type addressed in NRC Information Notice (IN) 2014-07 and are not subject to pressurization during Type A tests.
The staff noted that CR 543561 and CR 403558 addressed reviews of NRC IN 2014-04 and IN 2010-12, respectively. The CRs concluded that there was no evidence of Teflon existence or concerns for liner corrosion.
The staff reviewed VEPCO LAR dated August 12, 2013 and noted that the Fuel Transfer Tube penetration utilizes a bellows arrangement to establish seals between the containment liner, transfer cavity, spent fuel pool, and the penetration itself. However, it is sealed inside the Containment with a blind flange equipped with double-O-ring seal and Type B tested.
The staff reviewed WOs associated with OE Audit CRs and confirmed that the CRs were resolved with the exception of CR1052941, to be resolved as noted in Relevant Documents Reviewed Table.
CR540988 entry reviewed during the OE Audit. Description should read: Type A/B/C Database as-found/as-left leakage results not independently reviewed, resulting in errors being carried over to docketed info. Type B/C allowable leakage limits have not been exceeded.
Remove CR003267 entry from the OE Audit Report. Incorrect description entered. The CR is not relevant to the OE Audit of SLRA Section B.2.1.32.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP 10 CFR Part 50, Appendix J provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP XI.S4, 10 CFR Part 50, Appendix J. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
SLRA AMP B2.1.33, Masonry Walls Summary of Information in the Application. The SLRA states that AMP B2.1.33, Masonry Walls, is an existing condition monitoring program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S5, Masonry Walls. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this
report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2018-1338 Subsequent license renewal project aging management program evaluation report - Masonry Walls Revision 2 0-NSP-BS-005 Monitoring of structures Revision 10 CE-0087 Guideline for monitoring structures Revision 7 CCE-96-0013 Condition assessment of plant structures Revision 0 ET-S-07-0071 Condition assessment of plant structures (Second five-year inspection interval)
Revision 0 ETE-SU-2012-0046 Condition assessment of plant structures (Third five-year inspection interval)
Revision 0 ER-AA-101 Administrative procedure Revision 2 None Masonry Walls AMP Changes 02/11/2019 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the acceptance criteria program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing a RAI in order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.34, Structures Monitoring Summary of Information in the Application. The SLRA states that AMP B.2.1.34, Structures Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S6, Structures Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1339 Aging Management Program Evaluation Report - Structures Monitoring Revision 2 0-NSP-BS-005 Monitoring of Structures Revision 10 CE-87 Guidelines for Monitoring of Structures Revision 7 CE-37 Surry Settlement Monitoring Program Revision 0 0-OSP-FC-001 Spent Fuel Pool Leakage Evaluation Revision 0 0-CSP-PL-001 Subsurface Drain Chemistry Revision 4 SPS UFSAR Surry Power Station Updated Final Safety Analysis Report (UFSAR)
Revision 49 CCE-96-0013 Condition Assessment of Plant Structures - Baseline Inspection Revision 0 ET-S-07-0071 Condition Assessment of Plant Structures - 2nd - Five Year Inspection Interval Revision 0 ETE-SU-2012-0046 Condition Assessment of Plant Structures - 3rd - Five Year Inspection Interval Revision 0 WM-AA-100 Work Management Revision 31 CA 007181 Sample Results for Unit 2 Turbine Building (2-PL-P-14) exceeded the acceptance limit of < 500 ppm chlorides in accordance with 0-CSP-PL-001 03/26/2007 CCE-96-0013 Condition Assessment of Plant Structures Surry Power Station Units 1 and 2 Revision 0 /
12/19/1996 ET-S-07-0071 Condition Assessment of Plant Structures (Second Five-Year Inspection Interval)
Revision 0 /
06/26/2008
Document Title Revision / Date ETE-SU-2012-0046 Condition Assessment of Plant Structures (Third Five-Year Inspection Interval)
Revision 0 /
12/04/2012 WO 38079565601 Building and Structures Monitoring Report 08/28/2012 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit the staff made the following observation:
The staff reviewed work order No. 38079565601 and noted that the inspection report establishes quantitative inspection data and was conducted using comparable acceptance criteria from those recommended by the GALL-SLR Report. It also clarifies how the SLRA AMP is being consistent with the GALL-SLR Report recommendation for the monitoring and trending program element.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Structures Monitoring Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.35, Inspection of Water-Control Structures Associated with Nuclear Power Structures Summary of Information in the Application. The SLRA states that AMP B.2.1.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing condition monitoring program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plants. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1340 Surry subsequent license renewal project - aging management program evaluation report, Inspection of Water-Control Structures Associated with Nuclear Power Plants Revision 1 0-NSP-BS-005 Monitoring of structures Revision 10 0-STP-70.7 Annual intake canal liner visual inspection/acceptance test Revision 4 CE-0087 Guideline for monitoring structures Revision 7 GMP-M-150 Fabrication and installation of hangers, supports, and structures Revision 15 0-MPM-1901-01 High level intake structure screenwells and associated piping inspection Revision 31 0-MPM-1901-02 Low level intake structure screenwells 1D, 2A, 2B service water inspection Revision 9 0-NSP-BS-001 Erosion control inspection Revision 2 GMP-M-150 Fabrication and installation of hangers, supports, and structures Revision 15 MS-AA-WHS-131 Nuclear fleet administration procedure Revision 8 None Detail CR evaluation - Surry operating experience report by document 11/20/2018 ETE-SU-2012-0046 Condition assessment of plant structures - third five-year inspection interval Revision 0 ET-S-04-0086 Repair of intake canal earthen structure and concrete liner Revision 2 CCE-96-0013 Condition assessment of plant structures - Surry power station units 1 & 2 Revision 0 EWR 87-021 Recommendations for future maintenance of intake canal liner 03/03/1988 CA3049892 Additional guidance for the inspection of ASR in concrete is needed 02/02/2017 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit, the staff made the following observations:
The staff reviewed document No. EWR 87-021 and noted that the inspections for erosion control and the intake canal liner are performed annually. The staff also noted that the annual inspections frequency is more conservative than the frequency recommended by the GALL-SLR Report and are based on the recommendations for future maintenance of intake canal liner as documented in EWR 87-021.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.36, Protective Coatings Monitoring and Maintenance Summary of Information in the Application. The SLRA states that AMP B.2.1.36, Protective Coatings Monitoring and Maintenance, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.S8, Protective Coatings Monitoring and Maintenance. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed an enhancement associated with this AMP. The staff will document its review of the enhancement in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1341 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Protective Coating Monitoring and Maintenance Revision 0 1-MPT-1205-01 Unit One Containment Sump Inspection and Test Setup Revision 25 1-NPT-CT-102 Inspection of Containment Structure Revision 2 2-MPT-1205-01 Unit Two Containment Sump Inspection and Test Setup Revision 28 2-NPT-CT-102 Inspection of Containment Structure Revision 2 CM-AA-CRS-100
[Generic Safety Issue] GSI-191 Program Standards, Requirements, and Guidance for the Containment Recirculation Sump Revision 3 CM-AA-CRS-103 Containment Coating Condition Assessment Revision 4
Document Title Revision / Date CM-AA-CTG-10 Coating Program Revision 4 VPAP-1002 Quality Control (QC) Inspector Certification Program Revision 12 ME-0778 Post LOCA [Loss of Coolant Accident] Debris Transport to Containment Sump Strainer for Resolution of GSI-191 Revision 3 ME-0777 Debris Generation due to LOCA within Containment for Resolution of GSI-191 Revision 2 DQR-PGM-PGM-AA-CTG Fleet Lead & Site Owner Revision 4 ME-0790 GSI-191 Downstream Effects - Wear Analysis of ECCS Components Revision 3 CR1068099 U2 Containment Coating Assessment 2R27 05/10/2017 WO38103814713 U2 Containment Coating Assessment 2R27 Revision 0 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
In addition, the staff found that for the monitoring and trending, program elements, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing an RAI to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Protective Coatings Monitoring and Maintenance program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B.2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.E1, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. During the
audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1343 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 0 Cable Walkdown and Inspection Data Sheet ET-CEP-04-0021 Walkdown Visual Inspection of Non-EQ Cables at Surry Power Station Revision 1 ETE-SU-2016-1011 2016 Aging Management Review of Non-EQ Cable Inspections Revision 0 CR1035737 (LR Non-EQ Cable W/D Item) Cable Investigation/Evaluation Requested Revision 0 PI-AA-100-1004 Self-Assessment: Informal License Renewal/Aging Management SA 12/10/2015 CR1038564 NOD Audit Finding 16-04-01 NSL Admin Control not effective for changes for License Renewal Program Revision 0 CR1076642 NOD 17-04-03S follow-on: Each AMP Owner/Site Contact to verify/document adequate LR actions Revision 0 CR1065943 NEI 14-12 and NEI 14-13 not incorporated into Dominion Aging Management Program Revision 0 Surry Operating Experience Report by AMP, SLR-1343, XI.E1 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 11/14/2018 NESML-Q-270 NES Materials Engineering Laboratory Failure Analysis Report 07/18/1996 ER-SU-5909 SPS Program to Inspect Non-EQ Electrical Cables Revision 4 ETE-SLR-2018-1408 Surry Subsequent License Renewal - Position Paper -
Electrical Cables and Connections Insulation Types Revision 0 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective
actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits Summary of Information in the Application. The SLRA states that AMP B.2.1.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.E2, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1344 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Revision 0 ET-CEP-04-0021 Walkdown Visual Inspection of Non-EQ Cables at Surry Power Station Revision 1 ER-SU-5909 SPS Program to Inspect Non-EQ Electrical Cables Revision 4 ETE-SLR-2016-1409 Subsequent License Renewal Project Position Paper Revision 1 CR1038564 NOD Audit Finding 16-04-01NS: Admin control not effective for changes for License Renewal Program Revision 0 CR1016519 Triax Cable Connector broken Revision 0 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective
actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B.2.1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.E3A, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.
During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1345 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 1 ETE-CEP-2012-1007 Non-EQ Cable Monitoring, License Renewal Aging Management Program Revision 1 ER-SU-5909 SPS Program to Inspect Non-EQ Electrical Cables Revision 4 ETE-SLR-2015-1401 Subsequent License Renewal Position Paper - Non-EQ Inaccessible Power Cable - Surry Power Stations Revision 3 0-AP-3701 Abnormal Environmental Conditions Revision 7 0-MCM-1207 Pumping of Security and Electrical Cable Vaults Revision 13 CR002199 Water Intrusion in ESGR and Turbine Building 10/08/2006
Document Title Revision / Date CR011864 Safety Related Cables Submerged in Water 05/14/2007 CR011866 Safety Related Cable Submerged in Water/Manhole 01-EP-MH-2 05/14/2007 CR102577 Programmatic Work Request to Implement DCP 08-019 Upon Issue 06/30/2008 CR1038564 NOD Audit Finding 16-04-01NS Admin Control not Effective for Changes for License Renewal Program 05/26/2006 CR100446 01-EP-MH-1 Safety Related Cable Under Water 06/03/2008 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit the staff made the following observation:
The staff reviewed Detection of Aging Effects program element in ETE-SLR-2018-1345 and noted that this program element does not include a test matrix that documents inspection method, test methods, and acceptance criteria. GALL-SLR XI.E3A recommends a test matrix to be included. However, the Detection of Aging Effects program element in ETE-SLR-2018-1345 provides a listing of tests and future procedures to be developed for testing. During a telephone conference, Dominion committed to include a test matrix in the Detection of Aging Effects program element to be consistent with those in GALL-SLR XI.E3A.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B.2.1.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3B, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion had not yet fully developed the documents necessary to implement
this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1350 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 1 ER-AA-CBL-101 Evaluation and Testing of Low Voltage Cables Revision 3 0-AP-3701 Abnormal Environmental Conditions Revision 7 0-MCM-1207-01 Pumping of Security and Electrical Cable Vaults Revision 13 CR002199 Water Intrusion in ESGR and Turbine Building 10/08/2006 CR002382 Potential for Water in Duct Line L to MER-5 10/12/2006 CR008773 ESGR Duct Bank D Dewatering 03/16/2007 CR009213 Manhole #3 Electrical Penetration Seal Issues 03/23/2007 CR011864 Safety Related Cables Submerged in Water 05/14/2007 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B.2.1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3C, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1351 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 1 ER-AA-CBL-101 Evaluation and Testing of Low Voltage Cables Revision 3 0-AP-37.01 Abnormal Environmental Conditions Revision 7 0-MCM-1207-01 Pumping of Security and Electrical Cable Vaults Revision 13 0-MCM-1207-03 Inspection of Electrical Cable Vaults with Safety Related Cables Revision 3 CR002199 Water Intrusion in ESGR and Turbine Building 10/08/2006 CR002382 Potential for Water in Duct Line L to MER-5 10/12/2006 CR008773 ESGR Duct Bank D Dewatering 03/16/2007 CR009213 Manhole #3 Electrical Penetration Seal Issues 03/23/2007 CR007158 Grounded Motor Feeder Cables 02/05/2007 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.42, Metal Enclosed Bus Summary of Information in the Application. The SLRA states that AMP B.2.1.42, Metal Enclosed Bus, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-SLR Report AMP X1.E4, Metal Enclosed Bus. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exceptions and enhancements associated with this AMP. The staff will document its review of the exceptions to the GALL-SLR Report AMP and the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1346 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Metal Enclosed Bus Revision 1 ETE-SLR-2018-1106 Surry Subsequent License Renewal Project - Integrated Plant Assessment Report - Electrical Components Revision 1 0-ECM-0301-04 Emergency Bus Switchgear Maintenance Revision 12 0-ECM-0301-06 Transfer Bus D Switchgear Maintenance Revision 3 0-ECM-0301-07 Transfer Bus E Switchgear Maintenance Revision 1 0-ECM-0301-08 Transfer Bus F Switchgear Maintenance Revision 0 11448-1.15-46D Bus 1H General Arrangement Revision 4 11448-1.15-47C Bus 1J General Arrangement Revision 3 11448-1.15-22C Bus 2H General Arrangement Revision 5 11448-1.15-23C Bus 2J General Arrangement Revision 4 11448-FE-1W 480V One Line Diagram MCCs 1K1, 1K2, 1H - 1B, & 2K1 Revision 11
Document Title Revision / Date 11448-1.15-175A 480V Swgr Substation 1A1 and 1C2 Outline Details 6/11/1969 11448-FE-27A Arrangement Emergency Switchgear & Relay Rooms EL. 9 -
6 Revision 31 11448-FE-27B Arrangement Switchgear Room EL. 58 - 6 Revision 21 11448-FE-27C Arrangement Emer Swgr & Relay Rms EL 9 - 6 Revision 41 11448-FE-42C Conduit Details Service Building Revision 7 11448-FE-42E Cable Tray Plan & Sects Swgr Rm - Above EL. 58-6 Revision 7 11448-1.15-24C Indoor Bus Duct Layout Plan and Section Views Revision 1 D2817001 Bus Duct Layout Revision 3 D2817002 Unibus 5kV 1200A Termination Revision 2 D2817003 Unibus 5kV 3000A Termination Revision 2 NUS-0076 or SN-1057 Specification for 4160V Metalclad Switchgear 04/29/1968 NUS-373 or SN-390 Specification for 600V Metal Enclosed Bus Duct 03/08/1971 P-SURR-327949 1-EP-SW-F RTE 01/09/2013 US1034 Housing Assembly and Bus Bar Connection - Insulation Instructions Revision 2 US1035 Housing Assembly and Bus Bar Connection - Insulation Instructions2 Revision 2 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also verified Dominions claim that aspects of the detection of aging effects, program element not associated with the exceptions identified in the SLRA during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.43, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B.2.1.43, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1348 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 0 ETE-SLR-2016-1409 Subsequent License Renewal Position Paper - Electrical Cable Connections Sampling Methodology Revision 1 ETE-8U-2015-0082 Technical Basis for Predictive Analysis - Engineering Thermography Route Frequency Revision 0 NUS-2030 Nuclear Fleet Installation Specification for Electrical Installation
- Surry Power Station Unit 1 and 2 04/27/2017 ETE-SLR-2018-1106 Surry Subsequent License Renewal Project - Integrated Plant Assessment Report - Electrical Components Revision 1 0-ECM-1413-02 Low Head Safety Injection Pump Motor Maintenance Revision 16 During the audit, the staff verified Dominions claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA A1.43, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.44, High-Voltage Insulators Summary of Information in the Application. The SLRA states that AMP B.2.1.44, High-Voltage Insulators, is a new program with exception that will be consistent with the program elements in GALL-SLR Report AMP XI.E7, High-Voltage Insulators. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. During the audit, the staff reviewed an exception associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1410 Surry Subsequent License Renewal Project - Position Paper -
High-Voltage Insulators Revision 0 ETE-SLR-2018-1349 Surry Subsequent License Renewal Project - Aging Management Evaluation Report - High-Voltage Insulators Revision 0 N/A Substation Maintenance Manual - 2015 Edition N/A ETE-SLR-2018-1106 Surry Subsequent License Renewal Project - Integrated Plant Assessment Report - Electrical Components Revision 1 ETE-SLR-2015-1005 Surry Subsequent License Renewal Project - Regulated Events Report - 10 CFR 54.4(a)(3) Loss of All Alternating Current - Surry Power Station Revision 3 N/A Dominion Overhead Construction Manual April 2017 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified Dominions claim that aspects of the scope of program program element not associated with the exception identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.
During the audit the staff made the following observations:
The staff reviewed Dominions document ETE-SLR-2018-1410 referenced above and noted that the Preventive Actions program element of this AMP mentions that cleaning or coating of the high-voltage insulators will not be performed in the AMP. The staff will consider issuing an RAI to obtain the information necessary to determine whether Dominions SLRA AMP B.2.1.44, High-Voltage Insulators can be adequate to manage the associated aging effects.
The staff reviewed Dominions Substation Maintenance Manual referenced above and noted that switchyard equipment infrared scans, technical inspections, and corona scans are performed annually as part of the sub-station maintenance and inspection activities.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA A1.44, High-Voltage Insulators provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B3.1, Fatigue Monitoring Summary of Information in the Application. The SLRA states that AMP B3.1, Fatigue Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1301 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Fatigue Monitoring Revision 0 1/2-OSP-RC-001 Reactor Coolant System Cycle/Transient Log Review Revision 5 0-OSP-RC-001 RCS and PRZR Heatup/Cooldown Verification Revision 14 CH-99.500 Primary Chemistry Program, Surry Power Station, Chemistry Procedure, Dominion Revision 13 CN-PAFM-16-55 Transient Basis for Surry Units 1 and 2 80-year License Renewal Evaluations Revision 1 WCAP-18341-P Resolution of Surry Power Station Units 1 and 2 Time-Limited Aging Analyses for Subsequent License Renewal Revision 0 LTR-AMLR-18-10 Surry Units 1 and 2 Best Estimate Cycle Counting Program Transient Projections to 80 years of Plant Operation Revision 1 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective
actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA Fatigue Monitoring program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B3.2, Neutron Fluence Monitoring Summary of Information in the Application. The Subsequent License Renewal Application (SLRA) states that Aging Management Program (AMP) B3.2 Neutron Fluence Monitoring, is an existing program consistent with the program elements defined in the GALL-SLR Report AMP X.M2 Neutron Fluence Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will address issues identified but not resolved in this report in the safety evaluation report.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed the following relevant documents provided by Dominion.
Relevant Documents Reviewed Document Title Revision /Date ETE-SLR-2018-1302 Subsequent License Renewal Project - Aging Management Program Evaluation Report - Neutron Fluence Monitoring Revision 1 ER-AA-RVI-101 Administrative Procedure - Reactor Vessel Integrity Program Revision 4 SM-1529 RSAC Methodology for Pressurized Thermal Shock RPD Evaluation, Surry Power Station Revision 0 1-PT-4 Engineering Periodic Test Procedure - Reactor Vessel Exposure Revision 7 2-PT-4 Engineering Periodic Test Procedure - Reactor Vessel Exposure Revision 7 During the audit, the staff verified that for the program elements of the SLRA AMP that Dominion declared to be consistent, the acceptance criteria and corrective actions program elements are consistent with the corresponding elements of the GALL-SLR Report AMP During the audit the staff made the following observation:
The program basis document, ETE-SLR-2018-13202, indicated that for five of the program elements (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending,), Dominion is not monitoring neutron fluence of the reactor vessel internals (RVIs). However, Dominion did not identify an exception to the stated program elements.
The staff will consider issuing an RAI to obtain the information necessary to align these five elements with the corresponding program elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element associated with SLRA AMP B3.2, the staff independently searched the plant-specific database using keywords related to neutron fluence monitoring to identify any previously unknown or recurring aging effects. The staff did not identify any operating experience associated with SLRA AMP B3.2 based on the keyword search.
The staff also audited the UFSAR supplement summary description of SLRA AMP B3.2 in SLRA Section A2.2 Neutron Fluence Monitoring. The staff found that the UFSAR supplement did not summarize the applicants basis (i.e., exception for not monitoring neutron fluence levels of RVI components. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
SLRA AMP B3.3, Environmental Qualification of Electric Equipment Summary of Information in the Application. The SLRA states that AMP B3.3, Environmental Qualification of Electric Equipment, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X.E1, Environmental Qualification of Electric Components. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP.
The staff will document its review of the enhancements in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1303 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Environmental Qualification of Electric Equipment Revision 2 CM-AA-EQ-10 Fleet EQ Program Description Revision 3 CM-SU-100 Environmental Qualification Program Implementation Revision 4
Document Title Revision / Date EE-0014 Determination of Applicability of 10 CFR 50.49 and Specification Requirements for 10 CFR 50.49 Equipment or Safety-Related Equipment Located in a Mild Environment Revision 2 EQ-0079 Electrical Equipment Environmental Qualification Design Basis for North Anna and Surry Power Stations Revision 0 ETE-SLR-2015-1001 Surry Subsequent License Renewal Project - Regulated Event Report, 10 CFR 54.4(a)(3) Environmental Qualification Revision 2 N/A EQ Master List N/A ETE-SR-2017-0024 Evaluation of Conservatism for SPS Weed RTDs (QDR-S.8.17)
Revision 0 CR1050272 Inadequate EQ documentation for procurement of Validyne components Revision 0 CR1011377 Determine EQ Program Impact from Steris-Isomedix Radiation Dose - Part 21 Revision 0 PQE-08.17-P02 N/A Revision 0 CR573905 Qualified Life evaluation of CC RTDs removed from QDR 5-8.17 Revision 1 ETE-SR-2012-0044 Review of Qualified Life of ASCO Solenoid Operated Valve No.
2-CC-SOV-205B Revision 0 During the audit, the staff verified that for the program elements that Dominion declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
Staff Review of AMR Item Details Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:
SLRA Tables 3.2.2-1, Engineering Safety Features - Containment Spray - Aging Management Evaluation, and 3.2.2-2, Engineering Safety Features - Recirculation Spray - Aging Management Evaluation, state that cracking will be managed by the
ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program for stainless steel piping and piping components exposed to air-indoor uncontrolled.
The table below lists the documents that were reviewed by the staff and were found relevant to the review of these items. These documents were provided by Dominion.
Relevant Documents Reviewed Document Title Revision / Date NA Technical Requirements Manual Revision 42 During the audit the staff made the following observations:
The staff reviewed Table 6.1-1, Augmented Inspections, Item 2.2.1, Containment and Recirculation Spray Piping, from the Technical Requirements Manual and noted that:
(a) six nine-inch square patches will be examined by visual (VT-1) and surface examination; and (b) at least 25 percent of the inspection locations are inspected in each one-third portion of each in-service inspection 10-year interval. This input will be used in SER Section 3.2.2.2.4.
SLRA AMR Further Evaluation Item in SLRA Section 3.5.2.2.2.6, Reduction of Strength and Mechanical Properties of Concrete due to Irradiation Effects Summary of Information in the Application. SLRA Section 3.5.2.2.2.6, as supplemented by letter dated January 29, 2019, describes Dominions Further Evaluation of the aging effects of irradiation on the Concrete Biological Shield (or Primary Shield Wall) and the Reactor Vessel (RV) Support Steel Assembly. Based on the evaluation, the SLRA states that a plant-specific aging management program is not required to manage the effects of irradiation. This further evaluation is associated with SLRA Table 3.5.1, Item 3.5.1-097.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed plant documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date EPRI TR 3002013051 Irradiation Damage of the Concrete Biological Shield that Utilizes a Neutron Shield Tank - Basis for Concrete Biological Shield Wall for Aging Management May 2018 NUS-5 Specification for Mixing and Delivering Structural Concrete for Surry Power Station 01/10/1969 11448-FC-16A Interior Concrete Details EL -27 7 Reactor Containment, Surry Power Station Unit 1 Revision 7 11448-FC-16C Interior Concrete Details Sheet 2 Reactor Containment, Surry Power Station Revision 2
Document Title Revision / Date 11448-FC-16D Interior Concrete Details EL -3 0 Reactor Containment, Surry Power Station Revision 6 11448-FC-16E Interior Concrete Details EL 18 4 Reactor Containment, Surry Power Station Revision 10 11448-C-12 Reactor Containment - Interior Design Book/Concrete Revision 0 11448-C-13 Reactor Containment Interior Concrete 11/01/1989 11448-FV-7A Reactor Neutron Shield Tank Assembly, Surry Power Station Revision 6 11448-FV-7B Reactor Neutron Shield Tank Sheet 1, Surry Power Station Revision 7 11448-FV-7C Reactor Neutron Shield Tank Sheet 2, Surry Power Station Revision 6 11448-FV-7D Reactor Neutron Shield Tank Sheet 1, Surry Power Station -
Unit 1 Revision 8 11448-FV-7E Reactor Neutron Shield Tank Sheet 4, Surry Power Station Revision 4 ETE-SLR-2018-1269 Review of Shield Tank Configuration for SPS Units 1 and 2 Reactor Vessel Supports Revision 0 12/06/2018 ETE-SLR-2018-1270 Review of Loads on Neutron Shield Tank for SPS Units 1 and 2 Reactor Vessel Supports Revision 0 12/13/2018 ETE-SLR-2018-1271 Assessment of Radiation Effects on Reactor Vessel Supports for SPS Units 1 and 2 Revision 0 12/26/2018 PTR 2178-1525314-B4 Project Topical Report for Unit No. 1 Surry Power Station - Life Extension Evaluation of the Reactor Vessel Support 10/10/1986 NUS-96 Specification for Fabrication of Neutron Shield Tank for Surry Power Station 09/20/1968 NUS-368 Instructions for Installation of the Neutron Shield Tank for Surry Power Station 03/17/1970 15253.28-NM(B)-318-BB Stress Analysis of the Reactor Vessel Support for Life Extension Evaluation - Surry Unit 1, Stone & Webster Engineering Corporation Revision 0 07/16/87 CE-1640 Determination of Stiffness Value for Reactor Vessel Supports -
Surry 1 and 2 Revision 0 05/27/2003 CE-1642 The Effect of RPV Head Replacement on the PRV Support System (Neutron Shield Tank), Surry Units 1 and 2 Revision 0 05/27/2003 CE-1653 Review of Structural Adequacy of the Reactor Vessel Support Sliding Foot Assemblies - Surry Units 1 and 2 Revision 0 05/27/2003
Document Title Revision / Date CEM-0142 Sensitivity Evaluation of the Structural Adequacy of the Reactor Vessel Sliding Foot Assemblies for the Loss of Multiple Cap Screws, SPS Unit 1 Revision 1 Addendum 00B 04/30/2015 PVP2018-84786 Some Useful Mechanical Property Correlations for Nuclear Reactor Pressure Vessel Steels 07/20/2018 During the audit the staff made the following observations:
The staff reviewed Table 2-1 of EPRI Report 3002013051 and noted an apparent discrepancy between the maximum neutron fluence based on 72 EFPY [effective full power years] at the CBS wall surface of 1.18 X 1013 n/cm2 (E > 0.1MeV) reported therein and the corresponding value of 1.18 X 1013 n/cm2 (E > 1.0 MeV) reported in SLRA Section 3.5.2.2.2.6, as amended by letter dated January 29, 2019. During the in-office audit breakout session, Dominion acknowledged the discrepancy and noted that it would be corrected through an SLRA supplement. The staff notes, however, that NRC has not endorsed the content of the EPRI report but may use it for information only in reaching reasonable assurance for safety determination. The staff will also consider other related information that may be provided by Dominion.
- The staff reviewed Section 9.1 of Project Topical Report (PTR) 2178-1525314-B4 and noted an apparent discrepancy between the neutron fluence (E > 1 MeV) for 76.8 EFPY [effective full power years] at the outside surface (OD) of the Reactor Pressure Vessel (RPV) of 5.0 x 1018 n/cm2 (E > 0.1MeV) reported therein and the corresponding value of 5.0 x 1019 n/cm2 reported in SLRA Section 3.5.2.2.2.6, as amended by letter dated January 29, 2019, and whether the fluence value reported for the inner diameter of the NST is bounding for the two units. During the in-office audit breakout session, Dominion acknowledged the discrepancy and noted that it would be corrected through an SLRA supplement.
- The staff reviewed ETE-SLR-2018-1271 and noted that:
o Dominion reviewed its fracture mechanics evaluation (FME) documented in PTR 2178-1525314-B4 (based on fluence with E > 1.0 MeV) to verify that the assessment is applicable to both Units 1 and 2, claimed it confirms the assessment is consistent with NUREG-1509, and documents bounding conditions based on fluence projections through 80 years (68 EFPY) of plant operation and specific operating conditions.
o Dominion performed a re-evaluation of its FME in PTR 2178-1525314-B4 using the fracture mechanics approach discussed in Section 4.3 of NUREG-1509.
o The staff reviewed the SLRA Supplement dated January 29, 2019, and 15253.28-NM(B)-318-BB dated October 10, 1986 and noted that these documents do address effects fast neutron (E > 1.0 MeV) fluence on materials in the reactor vessel support steel assembly, although little is said regarding the effects of thermal (slow) neutrons in such materials. It is noted that report 15253.28-NM(B)-
318-BB states A non-conservative aspect of the above analysis is that only fast
neutrons (E>1MeV) are taken into account. As discussedslow neutrons (E<1MeV) can cause additional damage. The staff further notes the recommendation made in NUREG-1509 that embrittlement predictions should employ the complete energy spectrum to include any contribution from low-energy neutrons. The staff plans to further discuss with Dominion the effects of the entire fluence spectrum on the calculated critical stresses.
The staff reviewed 15253.28-NM(B)-318-BB report dated October 10, 1986 and noted that it states that a number of lubricants have been used in the sliding foot assembly and that insufficient data are presently available to assure their longevity. The staff intends to further discuss with Dominion the issue of longevity of lubricants as they affect structural performance of sliding foot assemblies, and the effects of the entire fluence spectrum on lubricants used in the sliding foot assemblies and elsewhere within the reactor cavity.
The staff reviewed PTR 2178-1525314-B4 and ETE-SLR-2018-1271 and noted that the embrittlement evaluation of the RV support system did not appear to explicitly account for potential degradations due to other mechanisms (e.g., corrosion of NST) through the end of the subsequent period of extended operation. The staff plans to discuss this issue further with Dominion.
During the in-office audit breakout session on April 3, 2019, Dominion stated it will provide, on the ePortal, additional information related to the issues discussed at the breakout. The staff will review the additional information and intends to also conduct an onsite audit on the irradiation effects on concrete and structural steel topic. For outstanding issues following the in-office and onsite audits, the staff will consider issuing RAIs or use voluntary docketed supplemental information (that may be provided by Dominion) to obtain the information necessary to determine the adequacy of the further evaluation addressing irradiation aging effects on the concrete bioshield wall and the reactor vessel steel supports assembly.
SLRA AMR Further Evaluation 3.6.2.2.2, Reduced Insulation Resistance Due to Age Degradation of Cable Bus Arrangements Caused by Intrusion of Moisture, Dust, Industrial Pollution, Rain, Ice, Photolysis, Ohmic Heating and Loss of Strength of Support Structures and Louvers of Cable Bus Arrangements Due to General Corrosion and Exposure to Air Outdoor Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following three AMR items discussed in SLRA 3.6.2.2.2 further evaluation section:
SLRA Table 3.6.1-029, Cable Bus: electrical insulation; insulators - exposed to air-indoor controlled or uncontrolled, air-outdoor SLRA Table 3.6.1-030, Cable Bus: external surfaces of enclosure assemblies composed of steel - exposed to air-indoor controlled or uncontrolled, air-outdoor SLRA Table 3.6.1-031, Cable Bus: external surfaces of enclosure assemblies composed of galvanized steel; aluminum - exposed to air-outdoor The SLRA 3.6.2.2.2 further evaluation section stated that SPS does use cable bus and is therefore not applicable.
The table below lists the documents that were reviewed by the staff and were found relevant to the review of these items. These documents were provided by Dominion.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1106 Surry Subsequent License Renewal Project - Integrated Plant Assessment Report - Electrical Components Revision 1 ETE-SLR-2016-1406 Surry Subsequent License Renewal Project - Position Paper -
Metal Enclosed Bus Revision 2 ETE-SLR-2018-1606 Surry Subsequent License Renewal Project - Further Evaluation Report - SRP Section 3.6 - Electrical and Instrumentation and Controls Revision 0 The staff reviewed Dominions further evaluation in SLRA Section 3.6.2.2.2, Reduced Insulation Resistance Due to Age Degradation of Cable Bus Arrangements Caused by Intrusion of Moisture, Dust, Industrial Pollution, Rain, Ice, Photolysis, Ohmic Heating and Loss of Strength of Support Structures and Louvers of Cable Bus Arrangements Due to General Corrosion and Exposure to Air Outdoor. This input will be used in SER Section 3.6.2.2.2.
SLRA AMR Further Evaluation 3.6.2.2.3, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following four AMR items discussed in SLRA 3.6.2.2.3 further evaluation section:
SLRA Table 3.6.2 item corresponding to SLRA Table 3.6.1-004, transmission conductors composed of aluminum, and steel exposed to air-outdoor SLRA Table 3.6.2 item corresponding to SLRA Table 3.6.1-005, transmission connectors composed of aluminum, and steel exposed to air-outdoor SLRA Table 3.6.2 item corresponding to SLRA Table 3.6.1-006, switchyard bus and connections composed of aluminum, copper, bronze, stainless steel, and galvanized steel exposed to air-outdoor SLRA Table 3.6.2 item corresponding to SLRA Table 3.6.1-007, transmission conductors composed of aluminum, and steel exposed to air-outdoor The table below lists the documents that were reviewed by the staff and were found relevant to the review of these items. These documents were provided by Dominion.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1106 Surry Subsequent License Renewal Project - Integrated Plant Assessment Report - Electrical Components Revision 1 N/A Dominion Overhead Construction Manual April 2017 ETE-SLR-2018-1410 Surry Subsequent License Renewal Project - Position Paper -
High-Voltage Insulators Revision 0 ETE-SLR-2015-1005 Surry Subsequent License Renewal Project - Regulated Events Report - 10 CFR 54.4(a)(3) Loss of All Alternating Current - Surry Power Station Revision 3 ETE-SLR-2018-1606 Surry Subsequent License Renewal Project - Further Evaluation Report - SRP Section 3.6 - Electrical and Instrumentation and Controls Revision 0 45-M-004 K Drawing: 3 1/2 Aluminum Tube Bus Detail - Surry Power Station 34.5 kV Yard 06/20/2001 N/A Substation Maintenance Manual 2015 - Edition N/A During the audit the staff made the following observations:
The staff reviewed photos provided by Dominion and noted that wooden poles are employed in some segments of the in-scope transmission conductors. The staff, subsequently verified that these structures are included in the SLRA Section B.2.1.34, Structures Monitoring aging management program.
The staff reviewed Dominions drawing 45-M-004 K, referenced above, and noted use of Belleville washers and non-grit inhibitor grease on transmission conductors and switchyard connections that alleviate loss of pre-load and corrosion of these connections.
The staff reviewed Dominions further evaluation in SLRA Section 3.6.2.2.3, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections. This input will be used in SER Section 3.6.2.2.3.
SLRA AMR Further Evaluation 3.6.2.3, Aging Management Review Results Not Consistent With or Not Addressed in the Generic Aging Lessons Learned for Subsequent License Renewal Report - Fuse Holders - Not Part of Active Equipment (Metallic Clamps and Insulation Material)
Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:
SLRA Table 3.6-017, Fuse holders (not part of active equipment): metallic clamps composed of various metals used for electrical connections exposed to air-indoor controlled or uncontrolled SLRA Table 3.6-018, Fuse holders (not part of active equipment): metallic clamps composed of various metals used for electrical connections exposed to air - indoor controlled or uncontrolled SLRA Table 3.6-022, Fuse holders (not part of active equipment): insulation material composed of electrical insulation material: bakelite; phenolic melamine or ceramic; molded polycarbonate, and other, exposed to air - indoor controlled or uncontrolled The SLRA 3.6.2.3 further evaluation section stated that SPS identified 5 fuse holders that require aging management review and based on the installed location, design configuration, operating service conditions, and operating experience, these fuse holders are not susceptible to the aging effects and mechanisms associated with metallic clamps and insulation material.
Therefore, SPS determined aging management activities for fuse holders are not required.
The table below lists the documents that were reviewed by the staff and were found relevant to the review of these items. These documents were provided by Dominion.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2016-1402 Surry Subsequent License Renewal Project - Fuse Holders Position Paper Revision 2 11448-FE-11F Wiring Diagram Vital Bus Distribution Panels Surry Power Station Unit 1 Revision 12 11448-FE-11D Wiring Diagram Vital Bus Distribution Panels IA & IIIA Surry Power Station Unit 1 Revision 14 11448-FE-1A3 One Line Diagram Switchyard Layout Surry Power Station Unit 1 & 2 Revision 22 11548-FE-11B Wiring Diagram Vital Bus Distribution Panels 2-II & 2-IV Surry Power Station Unit 2 Revision 36 11548-FE-11D Wiring Diagram Vital Bus Distribution Panels 2-IA & 2-IIIA Surry Power Station Unit 2 Revision 13 11548-FE-11F Wiring Diagram Vital Bus Distribution Panels Surry Power Station Unit 2 Revision 5 N/A 10 Amp Fuse in 2-EP-DB-AS-1 JB (photograph)
N/A
Document Title Revision / Date N/A 15 Amp Fuse in 2-EP-DB-2-IA Fuse JB (photograph)
N/A N/A Fuse F2 in App R Dist Panel JB N/A N/A Fuse F25 on FBII in Vital Bus Fuse JB (photograph)
N/A N/A Vital Bus 1-IA Fuse 21 (photograph)
N/A N/A Vital Bus Fuse JB (photograph)
N/A The staff reviewed Dominions further evaluation in SLRA Section 3.6.2.3, Aging Management Review Results Not Consistent With or Not Addressed in the Generic Aging Lessons Learned for Subsequent License Renewal Report - Fuse Holders - Not Part of Active Equipment (Metallic Clamps and Insulation Material). This input will be used in SER Section 3.6.2.3.
SLRA TLAA Section 4.1, Time-Limited Aging Analyses Summary of Information in the Application. SLRA Section 4.1, Time-Limited Aging Analyses, discusses the applicants methodology for identifying those plant analyses, evaluations, calculations, or assessments (AECAs) that qualify as TLAAs, consistent with the definition for TLAAs provided in 10 CFR 54.3(a), and for identifying those TLAAs that must be included and evaluated in the SLRA in accordance with 10 CFR 54.21(c)(1). SLRA Section 4.1 provides: (a) a list of those AECAs that qualify as TLAAs and have been identified as TLAAs in accordance with the requirement in 10 CFR 54.21(c)(1), and (b) a pointer to the sections or subsections in SLRA Chapter 4 that provides the applicants evaluation of the TLAAs and the basis for dispositioning the TLAAs in accordance with 10 CFR 54.21(c)(1)(i), (ii), or (iii). SLRA Section 4.1 also summarizes the applicants review that was performed to identify any regulatory exemptions that have been granted for the current licensing basis (CLB) in accordance with the requirements in 10 CFR 50.12 and are based on a TLAA, and the results of its regulatory exemption review, as required by 10 CFR 54.21(c)(2).
The staff audited SLRA Section 4.1, applicable information in the UFSAR, and supporting information, documents, and records to verify that Exelon has provided a comprehensive list of AECAs that qualify as TLAAs in accordance with 10 CFR 54.3(a) and has identified these AECAs as TLAAs in accordance with 10 CFR 54.21(c)(1). The staff also audited this information to: (a) verify that the applicant has appropriately identified any regulatory exemptions that were granted in the CLB under the requirements of 10 CFR 50.12 and are based on a TLAA, as required in accordance with 10 CFR 54.21(c)(2), and (b) for those 50.12 exemptions that are based on a TLAA, and for exemptions meeting these criteria, that the applicant has provided an appropriate evaluation of the exemptions in the SLRA justifying their continuation during the subsequent period of extended operation. As part of these efforts, the staff performed a search of the NRCs ADAMS document control database for any regulatory exemptions that may have been granted in the CLB under the requirements of 10 CFR 50.12 for the reactor units that are within the scope of the SLRA.
The staff will address any issues identified but not resolved in this audit report in the SER.
Audit Activities. During the NRC audit, the staff interviewed the applicants staff and reviewed documentation provided by the applicant. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date SLRA Section 4.1 Time-Limited Aging Analyses Revision 0 SLRA Section 4.2.5 Pressure Temperature Limits ASME Code Case N-514 Low Temperature Overpressure Protection, ASME Section XI, Division 1 March 1998 ASME Code Case N-629 Use of Fracture Toughness Test Data to Establish Reference Temperature for Pressure Retaining Materials,Section XI, Division 1 August 20, 2002 DOM-SLR-18-008 TLAA Keyword Search Revision 0 October 3, 2018 UFSAR Surry Power Station Updated Final Safety Analysis Report Revision 49, September 28, 2017 U.S. NRC Letter to Virginia Electric and Power Company Surry Power Station, Unit Nos. 1 and 2, Exemption From the Requirements of 10 CFR Part 50, Appendix G and 10 CFR Part 50, Section 50.61 (TAC Nos. MD2337 and MD2338)
June 27, 2007 (ADAMS Accession No. ML071160287)
Virginia Electric and Power Company Letter and License Amendment Request to U.S.
Nuclear Regulatory Commission, Document Control Desk Virginia Electric and Power Company (Dominion), Surry Power Station Units 1 and 2, License Amendment Request, Revised Cumulative Core Burnup Applicability Limit Heatup and Cooldown Curves, Low Temperature Overpressure Protection System (LTOPS) Setpoint, and LTOPS Enable Temperature May 6, 2010 (ADAMS Accession No. ML101310604)
U.S. Nuclear Regulatory Commission Correspondence Letter and Safety Evaluation to Mr. D. A. Heacock, President and Chief Nuclear Officer, Virginia Electric and Power Company Surry Power Station, Unit Nos. 1 and 2 - Issuance of Amendments Regarding Reactor Vessel Heat and Cooldown Curves for 48 Effective Full Power Years May 31, 2011 (ADAMS Accession No. ML11110A111)
Letter from J. P. OHanlon, Virginia Electric and Power Company, to U.S. NRC Virginia Electric and Power Company, Surry Power Station Units 1 and 2, Request for Exemption - ASME Code Case N-514, Proposed Technical Specifications Change, Revised Pressure/Temperature Limits and LTOPS Setpoints.
June 8, 1994
Summary of Audit Review for Identified TLAAs During the audit of the SLRA Section 4.1, relevant information in the UFSAR, and supporting information, the staff did not identify any AECAs that could potentially qualify as a TLAAs in accordance with 10 CFR 54.3(a) such that they might need to be identified and evaluated as additional TLAAs for the SLRA. The staff will document its basis for evaluating the applicant methodology for identifying TLAAs and the results of the TLAA search in Section 4.1 of the SER.
Summary of Audit Review of Exemptions that May Meet the Criteria in 10 CFR 54.21(c)(2)
During the audit of the SLRA Section 4.1, information in the UFSAR, and supporting information, the staff verified that the CLB does not include any regulatory exemptions granted in accordance with 10 CFR 50.12 that are based on a TLAA, such that the exemptions would need to be identified in the SLRA and evaluated in accordance with the requirements of 10 CFR 54.21(c)(2). The staff made the following observations during its review of the regulatory exemption basis discussions that were included in SLRA Section 4.1:
The staff observed that the CLB includes an exemption to apply ASME Section XI, Code Case N-629 to the CLB basis for performing reactor pressure vessel (RPV) component-specific calculations of RTPTS and adjusted reference temperature (ART), as applicable to the pressurized thermal shock (PTS) analyses and ART projections for the reactor units and performed in accordance with the calculations requirements in 10 CFR 50.61.
The staff noted that it would need further clarifications on whether the basis for requesting approval of this exemption was based on any AECA that might qualify as a TLAA.
The staff discussed this matter with the applicant during a scheduled audit teleconference dated February 14th, 2019, the applicant clarified that the exemption that was granted to apply ASME Section XI, Code Case N-629 to the PTS analyses pertained to the use of non-time dependent, alternative criteria that were used to establish the non-time-dependent initial RTNDT values (i.e. RTNDT(U) values) used as parameter inputs for the component-specific RTPTS calculations and ART projections.
The staff reviewed ASME Code Case N-629 and observed that the alternative methods in the Code Case are not based on time-dependent variables. The staff considers this audit matter to be resolved without the need for additional clarifications.
The staff will document its basis for evaluating the applicants methodology and results for identifying those regulatory exemptions that were granted under 10 CFR 50.12 and are based on a TLAA in Section 4.1 of the SER.
SLRA TLAA Section 4.2.1, Neutron Fluence Projections Summary of Information in the Application. The SLRA Section 4.2.1 states that the neutron fluence projections has been prepared with approved methodology and adhered with the Regulatory Guide 1.190. To verify this claim, the staff conducted the audit at Westinghouse office, 11333 Woodglen Drive Suite 202, Rockville, MD on April 2, 2019.
Audit Activities. During the NRC audit, the staff interviewed Westinghouses staff, Dr. Jianwei Chen and reviewed documentation provided by Westinghouse. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Date CN-REA-08-74 Pressure Vessel Neutron Fluence Evaluation to Support the MUR for Surry Unit 1 July 2009 CN-REA-08-75 Pressure Vessel Neutron Fluence Evaluation to Support the MUR for Surry Unit 2 July 2009 The documents reviewed clarified information that has been provided on the docket and as a result of the audit, the staff has no RAI.
SLRA TLAA Section 4.2.2, Upper Shelf Energy Summary of Information in the Application. SLRA Section 4.2.2, Upper Shelf Energy, provides the applicant evaluation of the time-limited aging analysis (TLAA) that assesses the projected degree of reduction in the upper shelf energy (USE) properties of reactor pressure vessel (RPV) base metal and weld components through the licensed lives of the reactor units. The TLAA (henceforth referred to as the TLAA on USE) applies to RPV base metal and weld components that are made from ferritic steel materials (e.g., carbon steels or low alloy steels) and are exposed to a reactor coolant with neutron flux environment, with neutron fluence being the time-dependent aging parameter that is evaluated in the TLAA. Dominion identified this analysis as a generic TLAA for the SLRA and dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date SLRA Section 4.2.2 Upper Shelf Energy Revision 0 SLRA Section A3.2.2 Upper Shelf Energy Revision 0 Framatome Proprietary Report No. ANP-3679P Low Upper-Shelf Toughness Fracture Mechanics Analysis of Surry Units 1 and 2 Reactor Vessels for Level A & B Service Loads at 80-years Revision 0 June 2018
Document Title Revision / Date Framatome Proprietary Report No. ANP-3680P Low Upper-Shelf Toughness Fracture Mechanics Analysis of Surry Units 1 and 2 Reactor Vessels for Level C & D Service Loads at 80-years Revision 0, June 2018 AREVA Proprietary Report No. BAW-2192P Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Level A & B Service Loads Supplement 1 Revision 0 December 2017 AREVA Proprietary Report No. BAW-2178P Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Level C & D Service Loads Supplement 1 Revision 0 December 2017 ASME Boiler and Pressure Vessel Code,Section XI, Appendix K Assessment of Reactor Vessels with Low Upper Shelf Charpy-Impact Energy Levels Latest edition and addenda of record incorporated by reference in 10 CFR 50.55a Title 10, Code of Federal Regulations, Part 50, Appendix G Fracture Toughness Requirements Current Edition in 10 CFR Part 50 Regulatory Guide 1.161 Evaluation of Reactor Vessels with Charpy Upper-Shelf Energy Less Than 50 Ft-Lb June 1995 Regulatory Guide 1.99 Radiation Embrittlement of Reactor Vessel Materials Revision 2, May 1988 Babcock and Wilcox Proprietary Report No.
BAW-2192PA Low Upper-Shelf Toughness Fracture Analysis of Reactor Vessels of B&W Owners Group Reactor Vessel Working Group For Load Level A & B Conditions Revision 0, April 1994 NRC Letter and Proprietary Safety Evaluation to Mr. G. L.
Lehmann, Chairman, B&W Owners Group Acceptance for Referencing of Topical Report, BAW-2192P, Low Upper-Shelf Toughness Fracture Analysis of Reactor Vessels of B&W Owners Group Reactor Vessel Working Group For Load Level A & B Conditions March 29,1994 Babcock and Wilcox Proprietary Report No.
BAW-2178PA Low Upper-Shelf Toughness Fracture Analysis of Reactor Vessels of B&W Owners Group Reactor Vessel Working Group For Load Level C & D Conditions Revision 0 April 1994 NRC Letter and Proprietary Safety Evaluation to Mr. G. L.
Lehmann, Chairman, B&W Owners Group Acceptance for Referencing of Topical Report, BAW-2178P, Low Upper-Shelf Toughness Fracture Analysis of Reactor Vessels of B&W Owners Group Reactor Vessel Working Group For Load Level C & D Conditions March 29,1994
Document Title Revision / Date AREVA Non-Proprietary Letter No. AREVA 01417 Transmittal of Information for Surry Specific Weld Wire Heat 299L44 (Capsule A5) from BAW-2313 Revision 7, PA-MSC-1200R0 Task 1 May 5, 2017 AREVA Non-Proprietary Report No. BAW-2313 Supplement to the B&W Fabricated Reactor Vessel Materials and Surveillance Data Information for Surry Unit 1 and Unit 2 Revision 7 Supplement 1 February 2017 PWR Owners Group Non-Proprietary Class 3 Report No. PWROG-16045-NP Determination of Unirradiated RTNDT and Upper-Shelf Energy Values of the Surry Units 1 and 2 Reactor Vessel Materials.
Revision 0 Westinghouse Non-Proprietary Class 3 Report No. WCAP-18028-NP Extended Beltline Pressure Vessel Fluence Evaluations Applicable to Surry Units 1 & 2 Revision 1 April 2018 Westinghouse Non-Proprietary Class 3 Report No. WCAP-18242-NP Surry Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity for Subsequent License Renewal Revision 2 July 2018 Westinghouse Non-Proprietary Class 3 Report No. WCAP-15130 Surry Units 1 and 2, WOG Reactor Vessel 60-year Evaluation Minigroup, Heatup and Cooldown Limit Curves for Normal Operation Revision 1 April 2001 PWR Owners Group Report No. PWROG-17090-NP Generic Rotterdam Forging and Weld Initial Upper Shelf Energy Determination Revision 0 March 2018 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). During the audit, the staff made the following observations:
During the audit of SLRA Section 4.2.2 and related reports, the staff observed that %-
Wt. Cu and Ni alloy contents reported for RPV beltline plate, forging or weld materials were based on the information compiled in PWR Owners Group Report No. PWROG-16045-NP, Revision 0. The staff observed that the Cu and Ni alloying elements for the RPV inlet and outlet nozzle-to-shell welds were those previously given in AREVA Report BAW-2313, Revision 7, Supplement 1.
The staff observed that the UUSE values were either based on the methods for establishing UUSE values in accordance with the methods defined in ASME Section III, the alternative methods in NRC branch position BTP 5-3, or for the RPV inlet and outlet nozzle forgings, the approved alternative General Electric (GE) methods for RPV nozzle forgings defined in EPRI Report No. BWRVIP-173, Revision 1-A. The staff observed that, for RPV nozzle-to-shell weld materials, the PWROG report references the UUSE and Cu and Ni alloy content bases established in AREVA non-proprietary Report No.
BAW-2313, Revision 7, Supp. 1. The staff observed that the values reported in the
AREVA report were based on a best effort basis by AREVA to track down the fabrication records for these RPV nozzle welds.
During the audit, the staff observed that the updated 1/4-thickness (1/4T) neutron fluences reported for the RPV components were based on the methodology and assessment provided in Westinghouse Non-Proprietary Class 3 Report No. WCAP-18028-NP, Revision 1. The staff observed that the 1/4T neutron fluences provided in the report were projected to the end of the subsequent period of extended operation for the reactor units (i.e., as projected to 68 effective full power years [68 EFPY]).
The staff observed that most ferritic material components in the Unit 1 and 2 RPVs would have USE values equal to or more than 50 ft-lb (i.e., as projected to 68 EFPY),
except for the following ferritic RPV components in Units 1 or 2 that were projected to have USE values less than 50 ft-lb at 68 EFPY:
o The upper shell-to-intermediate shell circumferential weld in the Unit 1 RPV. The staff observed the weld is fabricated from Weld Heat No. 25017; for this weld, the applicant projected a lower bound USE value of 39 ft-lb at 68 EPFY.
o Intermediate shell axial welds L3 and L4 and lower shell axial weld L1 in the Unit 1 RPV. The staff observed that these welds are fabricated from Weld Heat No.
8T1554; for these welds, the applicant calculated a lower bound USE value of 45 ft-lb at 68 EFPY.
o The intermediate-to-lower shell circumferential weld in the Unit 1 RPV. The staff observed that this weld is fabricated from Weld Heat No. 72445; for this weld the applicant projected a lower bound USE value of 32 ft-lb at 68 EPFY.
o Lower shell axial weld L2 in the Unit 1 RPV. The staff observed that Weld L2 is fabricated from Weld Heat No. 299L44; for weld L2, the applicant calculated a lower bound USE value of 38 ft-lb at 68 EFPY if Regulatory Position 1.2 in Regulatory Guide (RG) 1.99, Revision 2, is used as the basis for the calculation. In contrast, the staff observed that the applicant calculated a lower bound USE value of 42 ft-lb at 68 EFPY for Weld L2 if Regulatory Position 2.2 in RG 1.99, Revision 2, and the credible surveillance data for the weld heat are applied as the basis for the component-specific USE calculation for the weld.
o Three RPV inlet nozzle-to-upper shell welds in the Unit 1 RPV. The staff observed that three RPV inlet nozzle-to-upper shell welds are fabricated from Weld Heat No.
299L44; for these welds, the applicant calculated a lower bound USE value of 49 ft-lb at 68 EFPY if Regulatory Position 1.2 in Regulatory Guide (RG) 1.99, Revision 2, is used as the basis for the calculation. In contrast, the staff observed that the applicant calculated a lower bound USE value of 54 ft-lb at 68 EFPY for the RPV inlet nozzle-to-upper shell welds if Regulatory Position 2.2 in RG 1.99, Revision 2, and the credible surveillance data for the weld heat are applied as the basis the component-specific USE calculation for the weld.
The staff observed that the surveillance data used in the calculation meet the criteria for data credibility in RG 1.99, Revision 2. Based on the credibility of the surveillance data used in the calculation, the staff observed that the USE value for the RPV inlet nozzle welds meets the 50 ft-lb end-of-life USE requirement in 10 CFR Part 50, Appendix G if the
USE calculation is based on application of the applicable surveillance data for the weld heat.
o The upper shell-to-intermediate shell circumferential weld in the Unit 2 RPV. The staff observed that this weld is fabricated from Weld Heat No. 4275; for this weld the applicant calculated a lower bound USE value of 41 ft-lb at 68 EPFY.
o One hundred percent (100%) of intermediate shell axial weld L3 and fifty percent (50%) of the outside portion of intermediate shell axial weld L4 in the Unit 2 RPV.
The staff observed that 100% of weld L3 and 50% outside portion of weld L4 are fabricated from Weld Heat No. 72445; for the portions of these welds made from this heat of material, the applicant calculated a lower bound USE value of 42 ft-lb at 68 EFPY.
o Fifty percent (50%) of the inside portion of intermediate shell axial weld L4 and one-hundred percent (100 %) of lower shell axial welds L1 and L2 in the Unit 2 RPV. The staff observed that 50% of weld L4 and 100% welds L1 and L3 are fabricated from Weld Heat No. 8T1762; for the portions of these welds made from this heat of material, the applicant calculated a lower bound USE value of 43 ft-lb at 68 EFPY, as associated with the calculations for the lower shell axial welds L1 and L2.
o The RPV intermediate-to-lower shell circumferential weld in Unit 2. The staff observed that this weld is fabricated from Rotterdam Weld Heat No. 0227; for this weld, the applicant calculated a lower bound USE value of 43 ft-lb at 68 EFPY (the applicant calculated a lower bound USE value of 48 ft-lb at 68 EFPY if the credible surveillance data for the weld heat are used for the USE calculation).
The staff noted that, for the weld components identified above, the applicants TLAA on USE included a summary of the equivalent margins analysis (EMA) assessments for Service Level A & B and Service Level C & D loading conditions that were performed for the components in order to support the acceptability of the components through 68 EFPY and to meet the requirements for performing and accepting EMAs in 10 CFR Part 50, Appendix G.
The staff observed that the EMAs for RPV components with 68 EFPY USE values less than the 50 ft-lb are provided in two proprietary Framatome reports: (a) ANP-3679P, Revision 0, for the elastic-plastic fracture mechanics and flaw stability analyses of the welds under Service Level A & B loading conditions, and (b) ANP-3680P, Revision 0, for the elastic-plastic fracture mechanics and flaw stability analysis under Service Level C &
D loading conditions.
The staff observed that the EMA assessments for Service Level A & B loading conditions and Service Level C & D loading conditions are based on the methods and acceptance criteria established in Appendix K of the ASME Boiler and Pressure Vessel Code,Section XI. The staff observed that the Appendix K methods include applicable safety margins on applied pressure loads for Service Level A and B calculations.
The staff observed that method for calculating JR fracture toughness values over a series of crack extensions was based on a methodology developed by the B&W Owners Group (as defined in Proprietary Reports BAW-2192PA and BAW-2178PA. The staff observed that the applicable JR methodology was approved in the staffs safety evaluations for the BAW-2192PA and BAW-2178PA topical reports. The staff observed that the JR
parameter is the parameter that is impacted by increasing neutron fluence exposures.
The staff also noted that these methods were invoked as the same JR methods in Proprietary Reports ANP-3679P, Revision 0 and ANP-3680P, Revision 0.
The staff observed that the EMAs for the components under Service Level A and B loading conditions and Service Level C and D loading conditions satisfied the following acceptance criteria defined in ASME Section XI, Appendix K, as invoked by 10 CFR Part 50, Appendix G:
For assessments of flaw extension under these loading conditions, the criterion that:1 o Japplied < JR-0.1 (i.e., safety margin JR-0.1/Japplied) >1.0) o For assessments of flaw stability under these loading conditions, the criterion that:
o Japplied/a < JR/a Additionally, for level D loadings, the staff noted that the component-specific EMAs met the total flaw extension and internal pressure criteria specified in ASME Section XI, Appendix K, Paragraph K-5300(b). The staff also noted that, for time-dependent Service Level C and D transients and loading conditions, the EMAs satisfied the time dependent criteria stated in ASME Section XI, Appendix K, Paragraph K-5400.
The staff observed that the projected USE calculations for the ferritic components in the beltline of the RPVs are bounded by the USE calculation for the Unit 1 RPV intermediate-to-lower shell circumferential weld made from Weld Heat No. 72445.
The staff observed that the applicant projects a USE value of 32 ft-lb for this weld at 68 EPFY. However, the staff also observed that when the EMA analyses for Service Level A and B loads are applied to the Unit 1 and 2 components with USE values less than 50 ft-lb, the limiting material for the assessment changes to the EMA calculation for one of the axial welds used in the fabrication of the RPVs (i.e., the EMA is limited by the EMA calculation for the Unit 1 RPV lower shell axial weld L2, as fabricated for Heat No.
299L44 [SA-1526]).
The staff noted that the change in the limiting material results from the fact that the EMA methods in ASME Section XI, Appendix K apply a higher stress intensity factor on pressure (i.e., Kp value) to assessments of the RPV shell axial weld materials than that for corresponding EMA assessments of RPV shell circumferential welds materials. The higher Kp value applied to the EMA calculation for axial weld L2 results in a higher Japplied value than that calculated for the most limiting RPV circumferential weld material assessed in the EMA.
1 For the first equation expression below, Japplied is the J-integral elastic-plastic fracture toughness value (in units of in-lb/in2 [kJ/m2]) under applied pressure and thermal loadings, as assessed for a ductile crack extension of 0.10 inches (2.5 mm) beyond in initial postulated flaw size assumed in the analysis, and JR-0.1 is the J-integral fracture resistance for the material at a ductile flaw extension of 0.10 inches (in units of in-lb/in2 [kJ/m2]). For the second equation express given on the following page, the parameter Japplied/a represents the instantaneous rate of change in the Japplied value (i.e., Japplied) as a result of an incremental change in crack extension (a); similarly, the parameter Japplied/a is the instantaneous rate of change in the JR material fracture resistance value (i.e., Japplied value) as a result of an incremental change in crack extension (a). For the second parameter equation, the criterion is applied at the point where the Japplied versus a curve intersects with the JR versus a curve.
The staff observed that the applicants EMA calculation for the limiting RPV axial weld component in SPS Unit 1 and Unit 2 RPVs under Service Level A and B loading conditions resulted in a EMA safety margin (JR-0.1/Japplied) greater than 1.0.1 The staff also observed that the EMA also satisfied the flaw stability criterion for ductile tearing (i.e.,
Japplied/a < JR/a).
For the EMA evaluation of RPV components under Service Level C and D loading conditions, the staff observed that the applicants EMA is limited by the J-integral analysis calculation for the one of RPV shell welds in Unit 1 that is away from thickness discontinuities. For this component, the staff observed that that the applicant calculated an EMA safety margin of (i.e., JR-0.1/Japplied) greater than 1.0.2 The staff also observed that the EMA also satisfied the flaw stability criterion for ductile tearing (i.e., Japplied/a <
JR/a).
The staff will evaluate the acceptability of the component-specific USE calculations for 68 EPFY and the EMA results for RPV components with USE values less than 50 ft-lb at 68 EPFY as part of the staffs evaluation of the TLAA on USE in the SER.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects that could potentially impact the analysis in the TLAA. The staff noted that the TLAA is based solely on an assessment that a prolonged fluence exposure (as assessed and projected to the end of the subsequent period of extended operation [68 EPFY]) could have on USE properties of the components or the EMAs for some components. The staff did not identify any additional aging effects or aging mechanisms that could impact the methods or results of the USE or EMA analyses.
The staff also audited the UFSAR supplement summary description of the TLAA on USE provided in the SLRA Section A3.2.2, Upper Shelf Energy. The staff verified that the UFSAR supplement summary description for the TLAA provides a sufficient summary of the TLAA, including summaries of the USE results for RPV beltline and extended beltline components in Units 1 and 2 that were projected to 68 EFPY in accordance with 10 CFR 54.21(c)(1)(ii), and the basis for performing component-specific EMAs for those RPV beltline or extended beltline components whose projected USE values at 68 EPFY could not meet the end-of-life 50 ft-lb USE value criterion specified in the 10 CFR Part 50, Appendix G rule. For these components, the staff observed that the UFSAR provides a sufficient summary of: (a) the EMA basis for the components, (b) the applicants basis for projecting the component-specific EMAs to the end of the subsequent period of extended operation, as performed to comply with TLAA acceptance basis defined in Paragraph §54.21(c)(1)(ii) of the 10 CFR Part 54 rule, and (c) the basis why the component-specific EMA results satisfy the safety margin criteria in ASME Section XI, Appendix K, and the requirements for EMAs specified in Paragraph §IV.A.1.a of the 10 CFR Part 50, Appendix G rule.
1 Revision 0, that should be with-held from members of the general public in accordance with the proprietary information withholding requirements in 10 CFR 2.390. The staff is protecting the information according to the withholding requirements in 10 CFR.2.390.
2 The specific weld components evaluated in the EMAs and the specific JR-0.1/Japplied ratio values for the components under service level A and B, and C and D loading conditions have been identified AREVA Corporation as proprietary contents for AREVA Reports ANP-3679P, Revision 0, and ANP-3680P observed that the EMA also satisfied the flaw stability criteria for ductile tearing (i.e., Japplied/a < JR/a).
SLRA TLAA Section 4.2.3, Pressurized Thermal Shock Summary of Information in the Application. SLRA Section 4.2.2, Upper Shelf Energy, provides the applicant evaluation of the time-limited aging analysis (TLAA) that assesses the adequacy of the reactor pressure vessel (RPV) to withstand the consequences of a postulated pressurized thermal shock (PTS) event at the facility. The TLAA (henceforth referred to as the TLAA on PTS) applies to RPV base metal and weld components that are made from ferritic steel materials (e.g., carbon steels or low alloy steels) and are exposed to a reactor coolant with neutron flux environment, with neutron fluence being the time-dependent aging parameter that is evaluated in the TLAA. Dominion identified this analysis as a generic TLAA for the SLRA and dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date SLRA Section 4.2.3 Pressurized Thermal Shock Revision 0 SLRA UFSAR Supplement Section A3.2.3 Pressurized Thermal Shock Revision 0 10 CFR 50.61 Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events 2017 Edition of 10 CFR Framatome Report No.
BAW-2308 Initial RTNDT of Linde 80 Welds Materials (ADAMS ML032380455)
Revision 1 August 2003 AREVA Report No.
BAW-2308 Initial RTNDT of Linde 80 Welds Materials (ADAMS ML081270388)
Revision 2 January 2007 NRC Letter and Safety Evaluation to Mr. J. S.
Holm, Director of Regulatory Affairs, Framatome ANP Final Safety Evaluation for Topical Report (TR) BAW-2308, Revision 1, Initial RTNDT of Linde 80 Welds Materials August 4, 2005 NRC Letter and Safety Evaluation to Mr. G.
Bischoff, Manager Owners Group Program Office, Westinghouse Electric Company Final Safety Evaluation for Pressurized Water Reactor Owners Group (PWROG) Topical Report (TR) BAW-2308, Revision 2, Initial RTNDT of Linde 80 Welds Materials March 24, 2008
Document Title Revision / Date NRC Letter and Safety Evaluation to Mr. D. A.
Christian, Senior Vice President and Chief Nuclear Officer, Virginia Electric and Power Company Surry Power Station Unit Nos 1 and 2, Exemption From the requirements of 10 CFR Part 50 Appendix G, 10 CFR 50.61 June 27, 2007 Westinghouse Non-Proprietary Class 3 Report No.
WCAP-18028-NP Extended Beltline Pressure Vessel Fluence Evaluations Applicable to Surry Units 1 and 2 Revision 1 April 2018 Westinghouse Non-Proprietary Class 3 Report No.
WCAP-18242-NP Surry Units 1 and 2, Time-Limited Aging Analysis on Reactor Vessel Integrity for Subsequent License Renewal Revision 2 July 2018 PWR Owners Group and Westinghouse Non-Proprietary Class 3 Report No.
PWROG-16045-NP Determination of Unirradiated RTNDT and Upper-Shelf Energy Values of the Surry Units 1 and 2 Reactor Vessel Materials Revision 0 March 2017 PWR Owners Group Non-Proprietary Report No. ANP-2650 Updated Results for Request for Additional Information Regarding Reactor Pressure Vessel Integrity July 2007 NRC Letter and Safety Evaluation to Mr. D. A.
Heacock, President and Chief Nuclear Officer, Virginia Electric and Power Company Surry Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding Measurement Uncertainty Recapture Power Uprate September 24, 2010 Dominion License Amendment Request Virginia Electric Power Company (Dominion), Surry Power Station, Units 1 and 2, License Amendment Request, Revised Cumulative Core Burnup Applicability Limit for Heatup and Cooldown Curves, Lower Temperature Overpressure Protection System (LTOPS) Setpoint and LTOPS Enable Temperature May 6, 2010 NRC Letter and Safety Evaluation to Mr. D. A.
Heacock, President and Chief Nuclear Officer, Virginia Electric and Power Company Surry Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding Reactor Vessel Heatup and Cooldown Curves for 48 Effective Full-Power Years May 31, 2011 The methods for performing RPV component-specific calculations of the pressurized thermal shock reference temperature (RTPTS) and the component-specific acceptance criteria for RTPTS values are given in 10 CFR 50.61. During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of the TLAA in accordance with criterion specified in 10 CFR 54.21(c)(1)(ii).
During the audit, the staff made the following observations:
During the audit, the staff observed that the copper (Cu) and nickel (Ni) alloying chemistries for the RPV beltline components were based on the methods summarized in AREVA Report No. ANP-2650, and in PWR Owner Group Report No. PWROG-16045-NP, Revision 0, which relied on the data in ANP-2650. The staff also observed that the ANP-2650 report compiled additional RPV surveillance material data to update the Cu and Ni chemistries previously reported for Babcock and Wilcox (B&W) Master Integrated Reactor Vessel Surveillance Program (MIRVSP) Linde 80 weld materials in AREVA Report No. BAW-2308, Revision 1. The staff did not observe any discrepancies or issues with the methods used to establish the component-specific Cu and Ni values reported in the SLRA.
During the audit, the staff observed that the initial reference temperature (RTNDT) values (i.e., RTNDT(u)) used in the RTPTS calculations for RPV shell weld components (i.e., Linde 80 welds) made from either Weld Heats 299L44, 8T1554, 8T1762, or 72445 were based on the RTNDT(U) values specified in Framatome Report No. BAW-2308 Revision 1, or for Weld Heat 299L44, as amended in Revision 2 of the report. The staff observed that these reports were approved by staff in staff-issued safety evaluations dated August 4, 2005, and March 24, 2008, and that the applicant was granted a regulatory exemption (dated June 27, 2007) under the requirements in 10 CFR 50.12 to adopt these reports as part of the licensing basis for performing the RTPTS calculations for these weld components. The staff observed the reports provide the alternative B&W generic RTNDT(U) and u2 values that were approved by the staff.
The staff observed that the RTNDT(U) values for the unit-specific RPV upper shell forgings, RPV lower shell plates and intermediate shell plates, and RPV shell axial or circumferential welds made from Heat 25017 or from Rotterdam Drydock Company heats (Rotterdam welds) were as approved in the staffs SE of May 31, 2011, or as updated on PWROG-16045-NP, Revision 0.
The staff also observed that the applicant used the basis in PWROG-16045-NP, Revision 0, as the basis for establishing the RTNDT(U) values for the following unit-specific RPV extended beltline nozzle components: (a) the RPV inlet and outlet nozzle forgings in Units 1 and 2, (b) the portions of the Unit 1 RPV inlet nozzle welds made from Linde 80 Heat 299L44, (c) the Unit 1 RPV outlet nozzle welds and portions of the Unit 1 RPV inlet nozzle welds made from Heat 8T1762, (d) portions of the Unit 1 RPV outlet nozzle welds made from Heat 8T1554B, (e) Unit 2 RPV inlet nozzle welds made from Heat 8T1762, and (f) the Unit 2 RPV outlet nozzle welds made from a Rotterdam-specific heat. For RPV nozzles welds made from Linde 80 Heats 299L44, 8T1762, or 8T1554B, the staff noted that the RTNDT(U) values and the basis for establishing the RTNDT(U) values of the nozzle welds was different from RTNDT(U) values and basis (i.e., BAW-2308, Revision 1 and 2) for RTPTS values of RPV shell welds made from the same material heats.
The staff observed that the SLRA included RTPTS calculations for the RPV beltline and extended beltline components using the tabular chemistry factor-based methods defined 2 As defined in 10 CFR 50.61, u is the standard deviation of RTNDT(U), and is the standard deviation of the shift in RTNDT due to irradiation (RTNDT), used the margin term calculation, M=u2 + 2. Per 10 CFR 50.61, RTPTS = RTNDT(u) + RTNDT + M.
in the 10 CFR 50.61 rule and additional RTPTS calculations for those RPV base metal and weld components that have applicable site-specific or integrated RPV surveillance data for the heats of materials used in the fabrication of the components. The staff observed that this included surveillance-based calculations for the following components that are represented in either the Surry-specific surveillance programs or in the Babcock and Wilcox Master Integrated Reactor Vessel Surveillance Program (MIRVSP):
o The RPV lower shell plates in Unit 1 made from Plate Heat No. C4415: For these plates, the staff observed that the heat of material is represented by data compiled from tests on longitudinal test specimens contained in Surry Unit 1 Capsules X, T, and V. The staff observed that the surveillance data for this plate material are considered by the applicant to be credible in accordance with the credibility criteria established in the 10 CFR 50.61 rule. The staff observed that, based on the credibility of the data, the applicant set 3 to a value of 8.5 ºF, as permitted by the methods in the rule.
o RPV intermediate shell-to-lower shell circumferential weld in Unit 1 made from Weld Heat No. 72445; RPV intermediate shell axial weld L3 and the portion of RPV intermediate shell axial weld L4 in Unit 2 made from Linde 80 Weld Heat 72445. For these components, the staff observed that the heat of material is represented by data compiled from tests on weld specimens of the heat contained in MIRVSP capsules W1, CR3-LG1, CR3-LG2, PB1-V, PB1-S, PB1-R, and PB1-T. For this component, the staff observed that the RTPTS calculation is based on the basis in 10 CFR 50.61 and the approved methodology in Framatome in BAW-2308, Revision 1. The staff observed that the applicants RTPTS calculations for the components use the following input parameters bases: (a) set the RTNDT(U) value to a B&W generically-based value of -72.5 ºF, as established in BAW-2308, Revision 1; (b) over-riding the surveillance-based chemistry factor (CF) to a conservative value of 167 ºF (i.e.,
instead of applying a CF of 147.5 ºF using the applicable component fluence at 68 EFPY and the surveillance data for the weld heat); (c) setting the margin term I value to the approved value of 12.0 ºF established in BAW-2308, Revision 1; and (d) applying a full margin term value of 28.0 ºF for RPV welds made from Heat No.
72445.
o RPV lower shell axial weld L2 and the portions of the three RPV inlet nozzle-to-vessel shell welds in Unit 1 made from Weld Heat No. 299L44;. For these components, the staff observed that the heat of material is represented by data compiled from tests on weld specimens in Surry Unit 1 capsules X, V and T, and in MIRVSP capsules W1, A5, TMI1-C, TMI-E, TMI2-LG1 (with two sources of the heat),
and CR3-LG1. The staff observed that the surveillance data for this weld material are considered by the applicant to be credible in accordance with the credibility criteria established in the 10 CFR 50.61 rule. Thus, the staff observed that the applicant applied a value of 14 ºF for the RTPTS calculation of the most limiting Unit 1 RPV inlet nozzle weld made from this weld heat, as permitted by the rule.
However, the staff observed that when the surveillance data are applied to the RTPTS calculations for RPV lower shell axial weld L2 in Unit 1, the applicant set the value to a full value of 28 ºF; the staff observed this is permissible by the 10 CFR 50.61 3 As defined in 10 CFR 50.61, u is the standard deviation of RTNDT(U), and is the standard deviation of the shift in RTNDT due to irradiation (RTNDT), used the margin term calculation, M=u2 + 2. Per 10 CFR 50.61, RTPTS = RTNDT(u) + RTNDT + M.
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methods and represents a conservative practice for the calculation that applies to weld L2.
o The RPV intermediate shell plate in Unit 2 made from Plate Heat No. C4339-2: For this plate, the staff observed that the heat of material is represented by data compiled from tests on longitudinal and transverse test specimens contained in Surry Unit 2 Capsules X, V, and Y. The staff observed that the surveillance data for this material are not considered by the applicant to be credible in accordance with the credibility criteria established in the 10 CFR 50.61 rule. The staff observed that, based on the credibility of the data, the applicant conservatively set the value used in the margin term calculation to a full value of 17.0 ºF.
o The RPV lower shell-to-intermediate shell circumferential weld in Unit 2 made from Rotterdam Weld Heat No. 0227. For this plate, the staff observed that the heat of material is represented by data compiled from tests on the weld heat specimens contained in Surry Unit 2 Capsules X, V, and Y. The staff observed that the surveillance data for this weld material are considered by the applicant to be credible in accordance with the credibility criteria established in the 10 CFR 50.61 rule. The staff observed that, based on the credibility of the data, the applicant set the value used in the margin term calculation to a value of 14.0 ºF, as permitted by the methods in the rule.
The staff did not observe the existence of any additional capsule surveillance data beyond the data that had been accounted for in the surveillance-based, component-specific RTPTS calculations for the components listed above.
The staff observed the RTPTS calculations for the Surry Unit 1 RPV beltline and extended beltline components are limited by RTPTS calculation for RPV lower shell axial weld L2 (Heat No. 299L44), as projected to 68 EFPY and based on the use of credible surveillance data for the weld materials. For this component, the staff noted the applicant calculated a RTPTS value of 253.2 F at 68 EFPY. The staff observed that the applicants value is less than the acceptance criteria of 270 ºF stated for RPV base metal material and axial weld materials in the 10 CFR 50.61 rule.
The staff observed the RTPTS calculations for the Surry Unit 2 RPV beltline and extended beltline components are limited by RTPTS calculation for the RPV lower-shell-to-intermediate shell circumferential weld made from Rotterdam Weld Heat No. 0227. For this component, the staff observed that the applicant calculated an RTPTS value of 272.5 ºF at 68 EFPY, as calculated using the chemistry factor table for weld components given in the 10 CFR 50.61 rule. The staff noted that if the site-specific surveillance data for Rotterdam Weld Heat 0227 are used as the basis for the RTPTS calculation, the RTPTS value for the weld at 68 EPFY reduces to a value of 222.5 ºF, as based on confirmation of the credibility of the data in accordance with the credibility procedures in 10 CFR 50.61. The staff observed that the applicants RTPTS values projected for this component at 68 EFPY (i.e., one calculated using the chemistry factor in the 50.61 rule and one calculated in accordance with the applicable RPV surveillance data for the weld heat) meet the PTS screening criterion of 300.0 ºF for RPV circumferential weld components.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects that could potentially impact the analysis in the TLAA. The staff verified the TLAA is
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solely based on an assessment that a prolonged fluence exposure (as projected to and assessed at the end of the subsequent period of extended operation [68 EFPY]) could have on the RTPTS values that were calculated for the components. The staff did not identify any additional aging mechanisms that could impact the PTS analyses for the components.
The staff also audited the UFSAR supplement summary description of the TLAA on PTS provided in the SLRA Section A3.2.3, Pressurized Thermal Shock. The staff verified this description is consistent with the description provided in SRP-SLR Table 4.2-1 for these types of TLAAs.
SLRA TLAA 4.2.4, Adjusted Reference Temperature Summary of Information in the Application. SLRA Section 4.2.4, Adjusted Reference Temperature, provides Dominions evaluation of the adjusted reference temperature (ART) of the Surry Power Station (SPS), Units 1 and 2, reactor pressure vessel (RPV) beltline and extended beltline materials that accounts for neutron embrittlement through the end of the subsequent license renewal (SLR) period. ART is the sum of the initial nil-ductility reference temperature (RTNDT(U)) and the adjustment in RTNDT (RTNDT) that is caused by increasing neutron irradiation exposure to the components, and an additional safety term that is included in the calculation to account for uncertainties in the RTNDT(U) and RTNDT values. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii) to demonstrate that the ART analyses for the components have been projected to the end of the SLR period. To verify that Dominion provided adequate basis to support its disposition, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the safety evaluation report.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed the following relevant documents provided by Dominion.
Relevant Documents Received Document Title Revision and/or Date PWROG-16045-NP Determination of Unirradiated RTNDT and Upper-Shelf Energy Values of the Units 1 and 2 Reactor Vessel Materials March 2017 BAW-2313 Supplement to the B&W Fabricated Reactor Vessel Materials and Surveillance Data Information for Surry Unit 1 and Unit 2 -
Supplement 1 Revision 7 WCAP-18028-NP Extended Beltline Pressure Vessel Fluence Evaluations Applicable to Surry Units 1 & 2 Revision 1 WCAP-18242-NP Surry Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity for Subsequent License Renewal Revision 2
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Document Title Revision and/or Date Regulatory Guide 1.99 Radiation Embrittlement of Reactor Vessel Materials Revision 2 May 1988 During the audit of the TLAA, the staff verified that Dominion provided its basis that supports dispositioning the TLAA as 10 CFR 54.21(c)(1)(ii).
During the audit the staff made the following observations:
RPV inlet and outlet nozzles: As indicated in PWROG-16045-NP, Dominion determined RTNDT(U) of the inlet and outlet nozzle forgings in accordance with the GE method in NRC-approved topical report BWRVIP-173-A. For the nozzle-to-vessel welds (except for the SPS, Unit 2 outlet nozzle-to-vessel weld), Dominion determined RTNDT(U) values from the fabrication information in BAW-2313 Revision 7, Supplement 1, as referenced in PWROG-16045-NP, Revision 0. For the SPS, Unit 2 outlet nozzle-to-vessel weld, Dominion determined RTNDT(U) in accordance with Branch Technical Position (BTP) 5-3 of NUREG-0800.
RPV shell axial or circumferential welds made from Linde 80 Weld Heats 299L44, 72445, 8T1762, and 8T1554: Dominion applied the master curve methodology in BAW-2308, Revision 1-A and 2-A in lieu of RTNDT for welds that are made of Linde 80 flux metal. Use of the master curve methodology in lieu of RTNDT requires an NRC-approved exemption from the requirements in 10 CFR, Part 50, Appendix G and 10 CFR 50.61. By letter dated June 27, 2007 (ADAMS Accession No. ML071160287), the staff approved the exemption for Dominions use of the master curve methodology for SPS, Units 1 and 2.
RPV beltline materials: For the rest of the RPV beltline materials (not including inlet and outlet nozzles and Linde 80 axial or circumferential shell welds), Dominion determined RTNDT(U) in accordance with the ASME Code Section III or BTP 5-3.
In PWROG-16045-NP, Dominion cited from a 2010 license amendment request to revise pressure-temperature limit curves (ADAMS Accession No. ML101310604) a value of 20 °F for the standard deviation on RTNDT(U) (I) for the SPS, Unit 2 intermediate to lower shell circumferential weld (Heat #0227). However, Table 4.2.4-8 of the SLRA indicates a value of I = 0 °F for this weld because, as noted in the table, the RTNDT(U) is based on measured data. Appendix B of WCAP-18242-NP presents test data from certified test material reports and surveillance weld data to determine RTNDT(U) of weld Heat #0227. Per Regulatory Guide (RG) 1.99, Revision 2, if RTNDT(U) is determined from test data, I is to be estimated from the precision of the test method (typically 0 °F). Thus, Dominion set I = 0 °F for SPS, the Unit 2 intermediate to lower shell circumferential weld.
The neutron fluence values for 68 EFPY in Tables 2-2 and 2-3 of WCAP-18028-NP match the neutron fluence values for 68 EFPY in Tables 4.2.1-1 and 4.2.1-2 of the SLRA, which show the fluence values at the vessel inside surface at 68 EFPY. These fluence values are projected to the quarter thickness values for use in the ART calculations in Tables 4.2.4-5, 4.2.4-6, 4.2.4-7, and 4.2.4-8 of the SLRA.
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Dominion used credible surveillance data (including data from non-Surry plants) to determine the chemistry factor (CF) for weld Heats #299L44 and #72445, both Linde 80 welds. Tables 3-9 and 3-11 of WCAP-18242-NP show the calculations of CF for these two weld heats in accordance with Position 2.1 of RG 1.99, Revision 2. The safety evaluation (SE) of the master curve methodology in BAW-2308, Revision 1 (ADAMS Accession No. ML052070408) specifies a minimum CF value that must be applied when using the master curve technology for the Linde 80 welds. Thus, for weld Heat #72445, since the CF value determined from surveillance data is less than the CF value specified in the SE of BAW-2308, Revision 1, Dominion set the CF value to the minimum CF value in the SE of BAW-2308, Revision 1.
The staff observed and verified that the limiting material for SPS, Unit 1 is the Lower Shell Axial Weld L2 (Heat #299L44), with a 68 EFPY ART value of 219.4 °F at quarter thickness.
For SPS, Unit 2, the staff observed and verified that the limiting material is the Intermediate-to-Lower Shell Circumferential Weld (Heat #0227), with a 68 EFPY ART value of 210.7 °F at quarter thickness. Both values were determined from credible surveillance data using the guidance in Position 2.1 of RG 1.99, Revision 2.
During the audit of the operating experience program associated with the TLAA, the staff independently searched the plant-specific database using keyword related to ART to identify any previously unknown or recurring aging effects. The staff did not identify any operating experience associated with SLRA TLAA 4.2.4 based on the keyword search.
The staff also audited the UFSAR supplement summary description of the TLAA on ART provided in SLRA Section A3.2.4 Adjusted Reference Temperature. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA 4.2.5, Pressure-Temperature Limits Summary of Information in the Application. SLRA Section 4.2.5, Pressure-Temperature Limits, summarizes Dominions evaluation of the time-limited aging analysis (TLAA) related to pressure-temperature (P-T) limit calculations for the reactor pressure vessel (RPV) components in Surry Power Station, Units 1 and 2. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii), which requires the applicant to demonstrate that effects of aging on the intended function of the RPV components will be managed during the subsequent license renewal period. To satisfy this requirement, Dominion stated in the SLRA that it will update the P-T limits through the 10 CFR 50.90 process. Per the review guidance in SRP-SLR Section 4.2.3.1.4.3, to verify that the P-T limit methodology for the update will comply with the requirements in 10 CFR Part 50, Appendix G, the staff audited the TLAA.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed the following relevant documents provided by Dominion.
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Relevant Documents Received Document Title Revision / Date WCAP-18243-NP Surry Units 1 and 2 Heatup and Cooldown Limit Curves for Normal Operation Revision 2 WCAP-14177 Surry Units 1 and 2 Heatup and Cooldown Limit Curves for Normal Operation October 1994 WCAP-14040-A Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves Revision 4 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). The staff made the following observations:
The staff noted that even though Dominion is claiming 10 CFR 54.21(c)(1)(iii) for this TLAA, WCAP-18243-NP contains P-T limit curves developed for 68 effective full power years (EFPY), including curves for the inlet and outlet nozzle forging. These 68 EFPY curves are based on the KIC-based P-T limit methodology in WCAP-14040-A, Revision 4.
Based on an audit discussion with Dominion on April 1, 2019, the staff observed that Dominion indicated it may amend the disposition of the TLAA to 10 CFR 54.21(c)(1)(ii) and provide the appropriate supplements to the TLAA in a future amendment of the SLRA. The staff will evaluate such changes in the safety evaluation report for the SLRA.
During the audit of the operating experience program associated with the TLAA, the staff independently searched the plant-specific database using keywords related to P-T limits to identify any previously unknown or recurring aging effects. The staff did not identify any operating experience associated with SLRA TLAA 4.2.5 based on the keyword search.
The staff also audited the UFSAR supplement summary description of SLRA TLAA 4.2.5 in SLRA Section A3.2.5 Pressure-Temperature Limits. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA 4.2.6, Low Temperature Overpressure Protection Summary of Information in the Application. SLRA Section 4.2.6, Low Temperature Overpressure Protection, summarizes Dominions evaluation of the time-limited aging analysis (TLAA) that assesses the low temperature overpressure protection (LTOP) arming temperature and power operated relief valves (PORVs) pressure setpoint applicable to the Surry Power Station (SPS), Units 1 and 2 for the subsequent license renewal (SLR) period. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii), which requires the applicant to demonstrate that the analyses have been projected to the end of the SLR period. To verify that Dominion provided adequate basis to support its disposition, the staff audited the TLAA.
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Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed the following relevant documents provided by Dominion.
Relevant Documents Reviewed Document Title Revision / Date WCAP-18243-NP Surry Units 1 and 2 Heatup and Cooldown Limit Curves for Normal Operation Revision 2 WCAP-14040-A Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves Revision 4 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). The staff made the following observations:
The staff observed in Appendix D of WCAP-18243-NP that Dominion calculated the temperature enable value for the LTOP system using both ASME Code Cases N-514 and N-641, considering the appropriate projections to 68 effective full power years (EFPY). The temperature enable value projected to 68 EFPY is lower than the current temperature enable value in the Technical Specifications (TS) of SPS, Units 1 and 2.
The staff observed in Section 7 of WCAP-18243-NP that Dominion applied the KIC-based methodology in WCAP-14040-A, Revision 4, considering the appropriate 68 EFPY projections, to calculate the LTOP pressure setpoint for the PORVs. The calculated 68 EFPY pressure setpoint is higher than the current PORV pressure setpoint in the TS of SPS, Units 1 and 2.
Based on an audit discussion with Dominion on April 1, 2019, the staff observed that Dominion indicated it may amend the disposition of the TLAA to 10 CFR 54.21(c)(1)(i) or 10 CFR 54.21(c)(1)(iii), or otherwise supplement the TLAA in a future amendment of the SLRA.
The staff will evaluate such changes in the safety evaluation report for the SLRA.
During the audit of the operating experience program associated with the TLAA, the staff independently searched the plant-specific database using keywords related to LTOP to identify any previously unknown or recurring aging effects. The staff did not identify any operating experience associated with SLRA TLAA 4.2.6 based on the keyword search.
The staff also audited the UFSAR supplement summary description of SLRA TLAA 4.2.6 in SLRA Section A3.2.6 Low Temperature Overpressure Protection. The staff noted that although low temperature overpressure protection is listed as a generic TLAA in Table 4.1-2 Generic Time-Limited Aging Analyses of the SRP-SLR, there is no specific section in the SRP-SLR for it. The staff, however, verified that the description of the TLAA in the UFSAR supplement is consistent with the description in SLRA TLAA 4.2.6.
SLRA TLAA Section 4.3.2, ASME Code,Section III, Class 1 Fatigue Analyses Summary of Information in the Application. SLRA Section 4.3.2, ASME Code,Section III, Class 1 Fatigue Analyses, discusses the analyses for the Safety Class 1 components.
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Dominion dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(iii). To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1301 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Fatigue Monitoring Revision 0 1/2-OSP-RC-001 Reactor Coolant System Cycle/Transient Log Review Revision 5 0-OSP-RC-001 RCS and PRZR Heatup/Cooldown Verification Revision 14 CH-99.500 Primary Chemistry Program, Surry Power Station, Chemistry Procedure, Dominion Revision 13 CN-PAFM-16-55 Transient Basis for Surry Units 1 and 2 80-Year License Renewal Evaluations Revision 1 WCAP-18341-P Resolution of Surry Power Station Units 1 & 2 Time-Limited Aging Analyses for Subsequent License Renewal Revision 0 LTR-AMLR-18-10 Surry Units 1 & 2 Best Estimate Cycle Counting Program Transient Projections to 80 Years of Plant Operation Revision 1 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit, the staff made the following observation:
The staff reviewed WCAP-18341-P and noted that the applicant provided the applicable transients in the fatigue evaluation for each of the Safety Class 1 components and the CUF based on the 80-year transient cycle projections.
During the audit of the operating experience associated with the TLAAs, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the ASME Code,Section III, Class 1 Fatigue Analyses TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.3.3, ANSI B31.1 Allowable Stress Analyses Summary of Information in the Application. SLRA Section 4.3.3, ANSI B31.1 Allowable Stress Analyses, discusses the analyses for the reactor coolant systems primary loop and the balance-of-plant piping in scope for subsequent license renewal. Dominion dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(i). To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Received Document Title Revision / Date 1 & 2-OSP-RC-001 Reactor Coolant System Cycle/Transient Log Review Revision 5 CN-PAFM-16-55 Transient Basis for Surry Units 1 and 2 80-Year License Renewal Evaluations Revision 1 WCAP-18341-P Resolution of Surry Power Station Units 1 & 2 Time-Limited Aging Analyses for Subsequent License Renewal Revision 0 LTR-AMLR-18-10 Surry Units 1 & 2 Best Estimate Cycle Counting Program Transient Projections to 80 Years of Plant Operation Revision 1 WCAP-16990-P Surry Units 1 and 2 Measurement Uncertainty Recapture Power Uprate Project Engineering Report Revision 0 SIA 1600274.305 Selection of Sentinel Location Based on Environmentally Assisted Fatigue Screening Revision 3 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the Reactor Vessel Internals Fatigue Analyses TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.3.4, Environmentally-Assisted Fatigue Summary of Information in the Application. SLRA Section 4.3.4, Environmentally-Assisted Fatigue, discusses the analysis for the ASME Code,Section III, components and ANSI B31.1 piping that contact reactor coolant. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii). To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
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Relevant Documents Review During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of Dominions basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RAI.
Document Title Revision / Date ETE-SLR-2018-1301 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Fatigue Monitoring Revision 0 1/2-OSP-RC-001 Reactor Coolant System Cycle/Transient Log Review Revision 5 0-OSP-RC-001 RCS and PRZR Heatup/Cooldown Verification Revision 14 CH-99.500 Primary Chemistry Program, Surry Power Station, Chemistry Procedure, Dominion Revision 13 CN-PAFM-16-55 Transient Basis for Surry Units 1 and 2 80-Year License Renewal Evaluations Revision 1 WCAP-15607-P Evaluation of Pressurizer Insurge/Outsurge Transients for Surry Subsequent License Renewal - Environmental Assisted Fatigue Revision 0, Addendum 3 WCAP-18341-P Resolution of Surry Power Station Units 1 & 2 Time-Limited Aging Analyses for Subsequent License Renewal Revision 0 LTR-AMLR-18-10 Surry Units 1 & 2 Best Estimate Cycle Counting Program Transient Projections to 80 Years of Plant Operation Revision 1 SIA 1600274.305 Selection of Sentinel Locations Based on Environmentally Assisted Fatigue Screening Revision 3 EPRI 1024995 Environmentally Assisted Fatigue Screening August 2012 WCAP-18339-P Surry Units 1 and 2 ASME Section XI Appendix L Flaw Tolerance Evaluation for Safety Injection, Residual Heat Removal, Pressurizer Spray, Charging and Accumulator Lines August 2018 WCAP-18376-P Surry Power Station Units 1 & 2 Primary Equipment EAF Screening and Evaluations for Subsequent License Renewal Revision 0 SIA 1600274.306P Additional Environmentally Assisted Fatigue Analysis for Surry Revision 1
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During the audit, the staff made the following observation:
The staff reviewed WCAP-18376-P and noted that the sentinel location identification methodology includes identifying the location with the maximum screening CUFen for each applicable material type, in each transient section. The staff further noted that the methodology did not include a step that included criteria for a location of one material to bound a location of a differing material within a thermal zone.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the Environmentally-Assisted Fatigue TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.3.5, Reactor Vessel Internals Fatigue Analyses Summary of Information in the Application. SLRA Section 4.3.5, Reactor Vessel Internals Fatigue Analyses, discusses the analyses for the reactor vessel internals. Dominion dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(i). To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date 1/2-OSP-RC-001 Reactor Coolant System Cycle/Transient Log Review Revision 5 CN-PAFM-16-55 Transient Basis for Surry Units 1 and 2 80-Year License Renewal Evaluations Revision 1 WCAP-18341-P Resolution of Surry Power Station Units 1 & 2 Time-Limited Aging Analyses for Subsequent License Renewal Revision 0 LTR-AMLR-18-10 Surry Units 1 & 2 Best Estimate Cycle Counting Program Transient Projections to 80 Years of Plant Operation Revision 1 WCAP-16990-P Surry Units 1 and 2 Measurement Uncertainty Recapture Power Uprate Project Engineering Report Revision 0 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).
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During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the Reactor Vessel Internals Fatigue Analyses TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment Summary of Information in the Application. SLRA Section 4.4, Environmental Qualification of Electric Equipment, discusses the thermal, radiation, and cyclical aging analyses for the plant electrical and I&C equipment. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii). To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date ETE-SLR-2018-1303 Surry Subsequent License Renewal Project - Aging Management Program Evaluation Report - Environmental Qualification of Electric Equipment Revision 2 CM-AA-EQ-10 Fleet EQ Program Description Revision 3 CM-SU-100 Environmental Qualification Program Implementation Revision 4 EE-0014 Determination of Applicability of 10 CFR 50.49 and Specification Requirements for 10 CRR 50.49 Equipment or Safety-Related Equipment Located in a Mild Environment Revision 2 EQ-0079 Electrical Equipment Environmental Qualification Design Basis for North Anna and Surry Power Stations Revision 0 ETE-SLR-2015-1001 Surry Subsequent License Renewal Project - Regulated Event Report, 10 CFR 54.4(a)(3) Environmental Qualification Revision 2 N/A EQ Master List N/A ETE-SR-2017-0024 Evaluation of Conservatism for SPS Weed RTDs (QDR-S.8.17)
Revision 0 CR1050272 Inadequate EQ documentation for procurement of Validyne components Revision 0 CR1011377 Determine EQ Program Impact from Steris-Isomedix Radiation Dose - Part 21 Revision 0
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Document Title Revision / Date PQE-08.17-P02 N/A Revision 0 CR573905 Qualified Life evaluation of CC RTDs removed from QDR 5-8.17 Revision 1 ETE-SR-2012-0044 Review of Qualified Life of ASCO Solenoid Operated Valve No.
2-CC-SOV-205B Revision 0 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the SLRA TLAA, Environmental Qualification of Electric Equipment, provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis Summary of Information in the Application. SLRA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis, discusses the fatigue analysis for the containment liner plate in Section 4.6.1. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). SLRA Sections 4.6.2 and 4.6.3 state that, for SPS, metal containment fatigue TLAA is not applicable and there are no fatigue TLAAs for containment penetrations.
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date 11448-EA-62, Addendum 00C Reactor Containment Liner Fatigue Evaluation for 80-Year Plant Life, Surry Unit 1 and Unit 2 Revision 0 07/27/2017 11448-EA-62, Addendum 00B Reactor Containment Liner Fatigue Evaluation for Containment Type A Pressure Test for 60-Year Plant Life, Surry Unit 1 and Unit 2 Revision 0 04/25/2001 11448-EA-62, Addendum 00A Reactor Containment Liner Fatigue Evaluation for 60-Year Plant Life, Surry Unit 1 and Unit 2 Revision 0 09/08/2000
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Document Title Revision / Date 11448-EA-62 Reactor Containment Liner Pressure, Temperature and Seismic Stress Analysis, VEPCO Surry Units 1 and 2 11/20/1973 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
During the audit the staff made the following observation:
The staff noted from review of Section 11(b) of calculation 11448-EA-62, Addendum 00C, that for satisfying Condition 2 - Normal Operation Pressure Fluctuation, the calculation computed the cumulative damage effect due to 2000 cycles of normal operating pressure fluctuation (5.2 psi) and 100 cycles of Type A test pressure fluctuation (50.18 psi) to be 0.052, which is less than the cumulative damage acceptance criteria of 1.0. This input will be used in SER Section 4.6 after it is docketed.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the SLRA TLAA related to Containment Liner Plate Fatigue Analysis provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.1, Crane Cyclic Limits Analyses Summary of Information in the Application. SLRA Section 4.7.1, Crane Load Cycle Limits, discusses the analyses for the following cranes:
Containment polar cranes Containment annulus monorail Containment jib cranes Fuel building motor-driven platform Auxiliary building 10-ton monorail (27-foot level)
Auxiliary building 5-ton monorail (13-foot level)
Residual heat removal pump motor lifting lugs Spent fuel crane Dominion dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(i). To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff reviewed documentation provided by Dominion.
The staff reviewed the following relevant documents.
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Relevant Documents Reviewed Document Title Revision / Date DCP-02-068 SPS1 Polar Crane Uprate 03/20/2003 DCP-02-069 SPS2 Polar Crane Uprate 08/07/2003 TER-C5506-395 SPS NUREG-0612 Technical Evaluation Report 04/23/1984 ASME B30.11 Monorails and underhung Cranes 2010 ASME B30.16 Overhead Hoist (underhung) 2012 ASME HST-4-1999 Performance Standard for Overhead Electric Wire Rope Hoist 1999 E.O.C.I. Specification # 61 Specifications for Electric Overhead Travel Cranes 1961 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants July 1980 CMAA-70 Specification for Electric Overhead Traveling Cranes 1975 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). The staff found that sufficient information was available to complete its review of Dominions basis for its TLAA disposition. The staff will document its evaluation in the SER.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the crane cyclic loading TLAAs provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.2, Reactor Coolant Pump Flywheel Fatigue Crack Growth Analyses Summary of Information in the Application. SLRA Section 4.7.2, Reactor Coolant Pump Flywheel Fatigue Crack Growth Analyses, discusses the analyses for the reactor coolant pump flywheel. Dominion dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(i). To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant document.
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Relevant Documents Reviewed Document Title Revision / Date PWROG-17011-NP Update for Subsequent License Renewal: WCAP-14535A, Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination and WCAP-15666-A, Extension of Reactor Coolant Pump Motor Flywheel Examination Revision 2 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
The staff also audited the description of the Reactor Coolant Pump Flywheel Fatigue Crack Growth Analyses TLAA provided in the FSAR supplement. The staff verified this description is consistent with the generic description provided in the SRP-SLR.
SLRA TLAA Section 4.7.3, Leak-Before-Break Summary of Information in the Application. SLRA Section 4.7.3, Leak-Before-Break, discusses the analysis for the reactor coolant system primary loop piping associated with the TLAA. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues, which were identified but not resolved during this audit, in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date CN-PAFM-08-73 Surry Units 1 and 2 RCL LOCA, MS Break, and MFW Break Piping Stress Analysis and P, DW, Thermal, Seismic, and LBB Load Reconciliation and Surge Stratification Review for MUR Update Revision 0 CN-PAFM-10-36 Surry Units 1 and 2 RCL Piping Stress Analysis and Surge Stratification Analysis for RTSR Revision 1 ETE-NAF-2013-0087 Implementation of the NSSS Analyses with Updated Reactor Vessel Lower Key Stiffness in Support of NSAL-11-2 Resolution Revision 0
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Document Title Revision / Date ETE-NAF-2010-0079 Reload Transition Safety Report (RTSR): Westinghouse 15x15 Upgrade Fuel Design Transition at Surry Units 1 and 2 Revision 2 WCAP-17361-P Reload Transition Safety Report Surry Units 1 and 2 15x15 Fuel Upgrade Revision 1 WCAP-15550 Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for Surry Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 years) Leak-Before-Break Evaluation Revision 0 August 2000 WCAP-15550-P Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for Surry Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 years) Leak-Before-Break Evaluation Revision 1 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). However, the staff found that sufficient information was not available to complete its review of Dominions basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff did not identify any additional aging effects that would have an impact on the Dominions evaluation of the TLAA.
The staff also audited the description of the SLRA leak-before-break (LBB) analysis provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA LBB TLAA. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement description.
SLRA TLAA Section 4.7.4, Spent Fuel Pool Liner Fatigue Analysis Summary of Information in the Application. SLRA Section 4.7.4, Spent Fuel Pool Liner Fatigue Analysis, discusses the analysis for the spent fuel pool liner. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
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Relevant Documents Reviewed Document Title Revision / Date CE-1272, Addendum 00B Fuel Pool Liner Fatigue Evaluation for 80 Years Plant Life Revision 0 August 31, 2017 CE-1272, Addendum 00A Fuel Pool Liner Fatigue Evaluation for 60 Years Plant Life Revision 0 September 25, 2000 CE-1272 Analysis of Surry Fuel Pool Liner at 212 Degrees Fahrenheit Revision 0 August 7, 1996 CR 483122 On-going Spent Fuel Pool Liner Evaluation 07/27/2012 WO 38103198062 92 Day Freq. PT: Spent Fuel Pool Leakage Evaluation 07/09/2012 WO 38103256142 Request to generate work order for NDE of the Fuel Building Sump Liner Welds Completed 7/30/2012 ASME Code Section III, Division 1, Subsection NB Fatigue Acceptance criteria in, Paragraphs NB-3222.2, NB-3222.4, and NB-3228.5 2010 Edition During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). However, the staff noted that Table 2s in SLRA Section 3.5 appeared to exclude an aging management review (AMR) result line item that credits the TLAA for aging management. To obtain the necessary information, the staff will consider issuing an RAI or may use information Dominion offered to provide in an SLRA supplement.
During the audit the staff made the following observation:
The staff noted from Section 11.3 of calculation CE-1272, Addendum 00B that the cumulative damage due to fatigue effects (thermal cyclic loadings) for the controlling component (i.e., plate-stiffener weld) from the three design conditions described in SLRA Section 4.7.4 was calculated to be 0.75, which is less than the cumulative fatigue damage acceptance criteria of 1.0. This input will be used in SER Section 4.7.4 after it is docketed.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the plant-specific SLRA TLAA Spent Fuel Pool Liner Fatigue Analysis provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR for similar TLAAs.
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SLRA TLAA Section 4.7.5, Piping Subsurface Flaw Evaluations Summary of Information in the Application. SLRA Section 4.7.5, Piping Subsurface Flaw Evaluations, discusses the fatigue analysis for the embedded flaws associated with the TLAA.
Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues, which were identified but not resolved during this audit, in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date WCAP-18341-P Resolution of Surry Power Station Units 1 & 2 Time Limited Aging Analyses for Subsequent License Renewal Revision 0 September 2018 LTR-PAFM-17-14
Subject:
Surry Units 1 and 2 Piping Subsurface Flaw Evaluation for 80 years of Service, Subsequent License Renewal Revision 0 April 4, 2017 LR-1008/LR-2008 License Renewal Project Time-Limited Aging Analyses Review Surry and North Anna Power Stations Revision 1 7/30/2001 11448.65-DC-5 Fatigue Analysis of Weld Defects in Non-Safety-Related Piping Revision 0 06/08/1972 11448-392N Defective Weld in Feedwater Line 11448-14"-WFPD-9-601-95 On FP-2C 03/16/1972 11448.65-406N Fatigue Analysis Of Weld Defects in Non-Safety-Related Piping 05/22/1972 11448-393N Fatigue Propagation of Crack Caused By Unconsumed EB Ring, Surry Unit 1 03/22/1972 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). However, the staff found that sufficient information was not available to complete its review of Dominions basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
The staff also audited the description of the SLRA fatigue analysis provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA fatigue TLAA. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement description.
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SLRA TLAA Section 4.7.6, Reactor Coolant Pump Code Case N-481 Summary of Information in the Application. SLRA Section 4.7.6, Reactor Coolant Pump Code Case N-481, discusses the TLAA for the reactor coolant pump (RCP) casing to demonstrate that casing integrity remains valid for the subsequent period of extended operation (SPEO) and that the effects of aging on the intended function of the RCP casing will be adequately managed for the SPEO. Dominion dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(i).
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date WCAP-13045 Compliance to ASME Code Case N-481 of the Primary Loop Pump Casings of Westinghouse Type Nuclear Steam Supply Systems September 1991 PWROG-17033 Update for Subsequent License Renewal: WCAP-13045, Compliance to ASME Code Case N-481 of the Primary Loop Pump Casings of Westinghouse Type Nuclear Steam Supply Systems.
Revision 0 June 2018 ASME Code Case N-481 Alternate Examination Requirements for Cast Austenitic Pump CasingsSection XI, Division I March 5, 1990 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). However, the staff found that sufficient information was not available to complete its review of Dominions basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
The staff also audited the description of the SLRA TLAA Reactor Coolant Pump Code Case N-481 provided in the FSAR supplement. The staff verified this description is consistent with the description provided in SRP-SLR.
The staff also audited the description of the UFSAR supplement Sections 17.3.7.3 provided in SLRA Appendix A. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.7, Cracking Associated with Weld Deposited Cladding Summary of Information in the Application. SLRA Section 4.7.7, Cracking Associated with Weld Deposited Cladding, discusses the flaw tolerance analysis that evaluates the stability of subsurface cracks that potentially may be present in the reactor pressure vessel (RPV) welds used to RPV cladding to the RPV shell. Dominion identified this analysis as a plant-specific TLAA (henceforth the RPV Underclad Cracking TLAA) for the SLRA and dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
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To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date Westinghouse Non-Proprietary Class 3 Report No.
WCAP-15338-A A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants October 2002 PWR Owners Group (PWROG) Non-Proprietary Report No. PWROG-17031-NP Update for Subsequent License Renewal: WCAP-15338-A, A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants Revision 1 May 2018 Westinghouse Proprietary Class 2 Calculation No.
CN-AMLRS-10-3 Implementation of WCAP-16168-NP-A, Revision 2, for Surry Units 1 and 2 Revision 0 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). However, the staff found that sufficient information was not available to complete its review of Dominions basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations:
The staff reviewed relevant information in SLRA Section 4.7.7 and in Report Nos.
PWROG-17031-NP, Revision 1 and WCAP15338-A. The staff noted that the applicant is using the methodology and analysis in the PWROG report as the 80-year basis for the TLAA. The staff also noted that, in SLRA Section 4.7.7, the applicant identified that the 40-year design cycles for transients evaluated in the analysis bound the number of cycles projected to occur for these transients through 80 years of plant operations.
The staff noted that the PWROG report relied on for the TLAA includes flaw tolerance evaluations associated with the following three upset condition transients:
(a) inadvertent safety injection into the RPV, (b) reactor trip with cooldown and safety injection, and (c) excessive feedwater flow. However, the staff noted that updated final safety analysis report (UFSAR) Table 4.1-8 does not include these transients as analyzed transients for the unit-specific design bases. The staff observed that the applicant may need to provide additional clarifications on how the methodology in PWROG-17031-NP, Revision 1, addresses for flaw growth for those normal operating condition transients or upset condition transients that are within the scope of the CLB for the reactor units.
The staff reviewed relevant information in SLRA Section 4.7.7 and in Report Nos.
PWROG-17031-NP, Revision 1 and WCAP-15338-A. The staff noted that the methodology in the PWROG report assumes that an underclad crack will be stable for 80 years of plant operations if an applicant can demonstrate that:
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(a) for normal operating, upset, and test condition transients, the maximum applied stress intensity (KI, in units of ksi-inch) < KIa/10, where KIa is the fracture toughness property for crack arrest (in units of ksi-inch)
(b) for emergency and faulted condition transients, the maximum applied stress intensity (KI, in units of ksi-inch) < KIc/2, where KIc is the fracture toughness property for fracture initiation (in units of ksi-inch)
The staff also noted that the methodology in PWROG-17031-NP, Revision 1, assumes a lower-bound fracture toughness value of 200 ksi-in for the three upset condition transients and the four emergency or faulted condition transients evaluated in the report.
However, the staff noted that the applicant did not provide sufficient demonstration that the use of a 200 ksi-in fracture toughness value would be bounding for the unit-specific values of KIa that would be calculated as a function of (T - RTNDT) for each of the normal or upset condition transients evaluated in the PWROG report or the unit-specific values of KIc that would be calculated a function of (T - RTNDT) for each of the emergency or faulted condition transients evaluated in the report.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects that could potentially impact the analysis in the TLAA. The staff verified the TLAA is solely based on an assessment that cumulative cycle-based loadings could have on crack stability. The staff did not identify any additional aging mechanisms that could either impact the analysis or could potentially initiate cracks in the cladding welds from those already evaluated in the relevant reports (i.e., WCAP-15338-A and PWROG-17031-NP, Revision 1).
The staff also audited the FSAR supplement summary description of the RPV Underclad Cracking TLAA provided in the SLRA Section A3.7.7, Cracking Associated with Weld Deposited Cracking. Since this TLAA is defined as a plant-specific TLAA for the SLRA, the staff will evaluate the adequacy of SRLA Section A3.7.7 in the SER.
SLRA TLAA Section 4.7.8, Steam Generator High Cycle Fatigue Evaluation Summary of Information in the Application. SLRA Section 4.7.8, Steam Generator Tube High Cycle Fatigue Evaluation, discusses the high cycle fatigue analysis for the steam generator tubes. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
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Relevant Documents Reviewed Document Title Revision / Date WCAP-18379-P Surry Units 1 and 2 Steam Generator U-Bend Tube Vibration and Fatigue Assessment Revision 0 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the Steam Generator Tube High Cycle Fatigue Evaluation provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.9, Steam Generator Tube Wear Evaluation Summary of Information in the Application. SLRA Section 4.7.9, Steam Generator Tube Wear Evaluation, discusses the wear analysis for the steam generator tubes. Dominion dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).
To verify that Dominion provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff reviewed the following relevant documents.
Relevant Documents Reviewed Document Title Revision / Date CN-SGDA-02-121 The Effect of an Update to 2609 MWt NSSS Power for Surry Units 1 and 2 on Steam Generator Tube Wear October 2008 During the audit of the TLAA, the staff verified that Dominion has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the Steam Generator Tube Wear Evaluation provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
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Scoping and Screening Results - 2.3 Scoping and Screening Results: Mechanical Systems The following SLRA Sections were audited:
2.3.3 Auxiliary Systems 2.3.3.4 Service Water [focus area - flood control]
2.3.3.5 Circulating Water [focus area - flood control]
2.3.3.24 Plumbing [focus area - flood control]
2.3.3.29 Ventilation [focus area - Control Room Envelope]
2.3.3.37 Alternate AC [focus area - Fire Protection (10 CFR 50.48) & Station Blackout (10 CFR 50.63)]
2.3.3.38 Security [focus area - Fire Protection (10 CFR 50.48)]
2.3.4 Steam And Power Conversion Systems 2.3.4.1 Main Turbine (focus area -- 10 CFR 54.4(a)(2) for spatial interaction) 2.3.4.2 Electro-Hydraulic Control [focus area -- Fire Protection (10 CFR 50.48) and Anticipated Transients Without Scram (10 CFR 50.62)]
2.3.4.3 Lubricating Oil [focus area -- Fire Protection (10 CFR 50.48) and Anticipated Transients Without Scram (10 CFR 50.62)]
2.3.4.4 Main Steam [focus area - Fire Protection (10 CFR 50.48), Anticipated Transients Without Scram (10 CFR 50.62), and Station Blackout (10 CFR 50.63)]
2.3.4.5 Heating [focus area -- 10 CFR 54.4(a)(2) for spatial interaction]
2.3.4.6 Extraction Steam [focus area -- 10 CFR 54.4(a)(2) for spatial interaction]
2.3.4.7 Auxiliary Steam [focus area -- 10 CFR 54.4(a)(2) for spatial interaction; Fire Protection (10 CFR 50.48) and Station Blackout (10 CFR 50.63)]
2.3.4.8 Feedwater [focus area -- Fire Protection (10 CFR 50.48), Environmental Qualification (10 CFR 50.49), Anticipated Transients Without Scram (10 CFR 50.62), and Station Blackout (10 CFR 50.63)
Summary of Information in the Application. The SLRA Section 2.1 Scoping And Screening Methodology states in part:
The initial step in the scoping process was to define the entire plant in terms of systems and structures. Each of these identified plant systems and structures were then evaluated against the scoping criteria in 10 CFR 54.4(a)(1), (a)(2), and (a)(3), to determine if the system or structure performs or supports a safety-related intended function, if the system or structure failure could prevent the satisfactory accomplishment of a safety-related function, or if the system or structure performs functions that demonstrate compliance with the requirements of one of the five subsequent license renewal regulated events. The intended function(s) that are the bases for including systems and structures within the scope of subsequent license renewal were also identified.
Systems that contain mechanical components such as pumps, piping, valves, etc., are addressed as mechanical systems. A mechanical system was included within the scope of subsequent license renewal if any portion of the system met the scoping criteria in 10 CFR 54.4(a)(1), (a)(2), or (a)(3). Mechanical systems determined to be within the scope of subsequent license renewal were then further evaluated to determine those system components that are required to perform or support the identified system intended function(s). The in-scope
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boundaries of mechanical systems were identified and are described in Section 2.3. These boundaries are also depicted on the subsequent license renewal boundary drawings To verify this approach, the staff audited the above listed SLRA Sections.
Audit Activities. During the NRC audit the staff focused on those systems identified on the Surry Power Station PRA Risk Summary. The staff reviewed Subsequent License Renewal documentation provided by the applicant on the Exelon onecwcloud internet portal.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit.
Relevant Documents Reviewed Document Title Revision / Date SPS UFSAR Section 4.3.2 Reliance on Interconnected Systems; Chapter 9 Auxiliary and Emergency Systems in particular Appendix 9C Flood Control System; Chapter 10 Steam and Power Conversion Revision 49 9/28/2017 Surry Power Station PRA Risk Summary Unit 1 Core Damage Frequency (CDF); Unit 1 Large Early Release Frequency (LERF); Unit 2 Core Damage Frequency (CDF); Unit 2 Large Early Release Frequency (LERF)
SPS-RA.PR.3.A, Revision 2 SLRA Drawings 11448-SLRB-038B Sheet 1; 11448-SLRB-046D Sheet 1; 11448-SLRB-046D Sheet 3; 11448(11548)-SLRM-066A, Sheet 2;
8/9/2018 Exelon onecwcloud License Renewal Portal SLR Project Regulated Event Report for 10CFR54.4(A)3 Fire Protection; SLR Project Regulated Event Report for 10CFR54.4(A)3 Environmental Qualification; SLR Project Regulated Event Report for 10CFR54.4(A)3 ATWS; SLR Project Regulated Event Report for 10CFR54.4(A)3 SBO.
Revision 1 Revision 2 Revision 1 Revision 2 During the audit, the staff interviewed the applicants staff during five different breakout sessions. Two of these breakout sessions focused on the systems and structures that comprise the Flood Control Systems as detailed in the SPS UFSAR Appendix 9C. Another breakout sessions discussion focused on the Control Room Envelopes pressure boundary. The discussion of the two residual breakout sessions focused on the Steam and Power Conversion systems and the diesel generators of the Alternate AC system and the Security system.
As a result of the audit, the applicant posted on the Exelon onecwcloud internet portal additional license renewal related documentation in particular with respect to the boundaries of the CRE and to the plant program that governs Control Room Habitability. In addition, one SLRA deficiency was identified from the two breakout sessions that focused on Flood Control Systems.
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The staff cited the following UFSAR excerpt from Appendix 9C.1.2:
Fire Main Deflector A six-inch fire protection line runs along the turbine building north wall above the mezzanine level near the ESGR opening. To prevent water from spilling into the ESGR side of the dike located at the ESGR entrance, a flow directing pipe sleeve around the six inch line direct water to either end of the dike surrounded area.
The staff noted that Flood Barrier is neither identified as an Intended Function in SLRA Table 2.3.3-34 Fire Protection nor FLB in SLRA Table 3.3.2-34 Auxiliary Systems - Fire Protection
- Aging Management Evaluation. The applicant agreed that this pipe sleeve needs to be added to the SLRA as a component requiring aging management. To obtain the necessary information, the staff will consider issuing RAIs. The staffs final review will be documented in the SER.
Scoping and Screening Results - 2.3.1 Reactor Vessel, Internals, and Reactor Coolant System, and 2.3.2 Engineered Safety Features Summary of Information in the Application. SLRA Section 2.3.1, Reactor Vessel, Internals, and Reactor Coolant System, and 2.3.2, Engineered Safety Features provide the systems, structures, and components subject to aging management review (AMR). Dominion dispositioned the results in accordance with 10 CFR 54.4 and 54.21.
To assure if the applicant has prepared the information to meet the regulatory requirements, the staff audited the SLRA Section 2.3.1 and 2.3.2.
Audit Activities. During the NRC audit, the staff interviewed with Dominions staff on the deviations between SLRA and LRA for the in-scope SSC and associated intended functions below:
Relevant Documents Reviewed SSC SLRA vs. LRA Deviation Seal table in Reactor Vessel (SLRA Table 2.3.1-1 vs. LRs Table 2.3.1-2)
Intended function changed from LRAs Pressure Boundary to Structural Support Control Rod Guide Tube Split Pins, Diffuser Plate, Head and Vessel Alignment Pins, Head Cooling Spray Nozzles and Instrument Guide Tubes in LRA Table 2.3.1-3.
Identified components are not in SLRA Table 2.3.1-2 No additional measures components in SLRA Table 2.3.1-
- 2.
Identified components are not in LRA.
Heat exchanger (tubes) in SLRA Table 2.3.1-3.
Intended function of Heat Transfer not included Pressurizer (spray nozzle thermal sleeve) and (surge nozzle thermal sleeve) in SLRA Table 2.3.1-3.
Intended function changed from Pressure Boundary in LRA Table 2.3.1-4 to Limit Thermal Cycling in SLRA Table 2.3.1-3
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SSC SLRA vs. LRA Deviation Flow element in SLRA Table 2.3.2-1.
Intended function of Restricts flow not included as LRAs Heat Exchanger (tube) in SLRA Table 2.3.2-1.
Not included as LRAs Fuel Pit Cooling (FC) in SLRA Se. 2.3.2.
Not included as LRAs Filters/Strainers, Flow Element, Instrument Valve Assemblies and Pump Seal Coolers in LRA Table 2.3.2-4.
Identified components are not in SLRA Table 2.3.2-3 Instrument Valve Assemblies and Sump Screens in LRA Table 2.3.2-5.
Identified components are not in SLRA Table 2.3.2-4 The staff reviewed the documentation provided by Dominion on the above issues. The staff has determined that some of the information discussed and reviewed in the audit is necessary for the staff to make a finding and will be requested through the RAI process.
During the NRC audit, the staff interviewed Dominions staff and reviewed documentation provided by Dominion. The staff proposed the following questions and received the responses on 2/13/2019.
- 1. General: What are the differences in the license renewal boundary drawings between Subsequent License Renewal Application (SLRA) and License Renewal Application (LRA) for Sec. 2.3.1 and 2.3.2?
Dominion used the original LRA drawings as the starting point for the SLRA drawings.
Components that were shown within scope in the first LRA were not omitted from scope unless a design or licensing change occurred that removed them or removed their function. The original LRA drawings did not identify any (a)(2) spatial scoping (neither leakage boundary nor directly attached piping that provides support), which is shown in orange on the SLRA drawings.
- 2. General: What are the differences in the component types & intended functions between SLRA and LRA for Sec. 2.3.1 and 2.3.2?
Dominion did not attempt to recreate the same component types and functions as the original LRA. In some cases, we broke components into subcomponents, named them to better correspond with drawing labels, or grouped components to better align with GALL/SRP or to simplify the presentation. Additionally, the original LRA had a separate section for the pressurizer; the original LRA grouped fuel pit cooling with the ESF systems. These presentations are not how the current GALL/SRP is arranged.
- 3. For the Seal table in Reactor Vessel (SLRA Table 2.3.1-1, page 2-57), why has the intended function has been changed from LRAs Pressure Boundary to Structural Support (see LRs Table 2.3.1-2 on LR page 2-133)?
Review of the construction of the seal table revealed that the pressure boundary is provided by the thimble tube conduits that penetrate, and are welded to, the seal table.
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Thus, the seal table is not wetted, and does not perform a pressure boundary function, but does provide support to the thimble tube conduits. See WCAP 15268 Fig 2-2 on p. 7 (pdf p. 17) in the Reactor Vessel references in the portal.
- 4. As compared to LRAs Table 2.3.1-3 (Page 2-135), it seems that the Control Rod Guide Tube Split Pins, Diffuser Plate, Head and Vessel Alignment Pins, Head Cooling Spray Nozzles and Instrument Guide Tubes are missing from SLRAs Table 2.3.1-2.
Dominion aligned the reactor vessel internals components to the component names and management categories in LTR-AMLR-17-35-NP (Transmittal of Preliminary Results from the MRP-191 Expert Panel Review in Support of Subsequent License Renewal for Surry Units 1 and 2). The split pins are now called guide tube support pins. Diffuser plate, head and vessel alignment pins, head cooling spray nozzles, and upper instrumentation conduit and support (tubes, conduits, flange base, locking caps and support tubes) are now categorized No additional measures components, and are grouped with a generic component of that name.
- 5. In SLRA Table 2.3.1-2 (page 2-59), clarify why there is No additional measures components with intended functions of Flow Distribution and Structure Support.
As above, Dominion aligned the reactor vessel internals components to the component names and management categories in LTR-AMLR-17-35-NP (Transmittal of Preliminary Results from the MRP-191 Expert Panel Review in Support of Subsequent License Renewal for Surry Units 1 and 2). This was done to facilitate review against the MRP, which requires No additional measures for aging management of these components.
- 6. In SLRA Table 2.3.1-3 (Page 2-61), verify that the intended function for Heat exchanger (tubes) should include Heat Transfer.
No; Reactor coolant pump operation is not required, and the RCP lubricating oil heat exchangers are not required to remove heat to support any intended function. The cooling water supply is from the safety-related component cooling system, so a pressure boundary function maintains the CC system integrity. The stator coolers were assigned a heat transfer function because they remove heat from air that exits the motor stator, and limit heat input into containment.
- 7. In SLRA Table 2.3.1-3 (Page 2-62), the Pressurizer (spray nozzle thermal sleeve) and (surge nozzle thermal sleeve) are specified with Limit Thermal Cycling but they were specified with Pressure Boundary in LRA Table 2.3.1-4 (Page 2-138). Why they are different?
Dominion did not attempt to achieve this level of consistency with the first LRA. The writers of the first LRA may have interpreted thermal sleeve function as supporting the long-term pressure boundary function of the piping in which they are installed. However, the thermal sleeves do not perform a pressure boundary function themselves, so they were assigned a Limit Thermal Cycling function, which seems more descriptive of their function.
- 8. In SLRA Table 2.3.2-1 (page 2-74), verify that the Flow element should be included with Restricts flow function?
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No; the flow elements with an SI function are CS-FS-102A(B), shown highlighted in orange on 11448-SLRM-084A Sh. 1 grid A7 & B-7, and (for Unit 2) CS-FS-202A(B),
shown highlighted in orange on 11548-SLRM-084A Sh. 1, grid A-7 & B-7. These flow elements and the associated piping are outdoors, and function to provide structural support to the attached safety-related piping that connects to the refueling water storage tanks. The flow elements and associated nonsafety-related piping have no other license renewal intended function. Note that there is an Orifice component type that performs a Restricts Flow function.
- 9. In SLRA Table 2.3.2-1 (Page 2-74), verify that Heat Exchanger (tube) should be included.
Similar to the above flow element: the affected heat exchangers are the refueling water refrigeration unit shells, which are shown on the same drawings listed above, and act as base-mounted components (equivalent anchors) for the attached safety-related piping.
The tubes perform no license renewal intended function.
- 10. In SLRA Table 2.3.2-2 (Page 2-75), verify that Pump (seal cooler) should be included.
The recirculation spray seal coolers are externally mounted air-cooled coils of copper alloy tubing without any shell or channel. The only component unique to the seal coolers is the tube, which is listed above as Heat exchanger (seal cooler - tube). See the excerpt from DCP 91-027 in the recirc spray reference folder in the portal.
- 11. Justify why Table 2.3.2-2 Fuel Pit Cooling (FC) is included in the LRA but not in SLRA Sec. 2.3.2.
The first LRA grouped the fuel pit cooling system with the ESF systems. The fuel pool cooling system is addressed as an Auxiliary system in SLRA section 2.3.3.2 for consistency with GALL, which addresses the system in section VII.A3.
- 12. As compared to LRAs Table 2.3.2-4, it seems that Filters/Strainers, Flow Element, Instrument Valve Assemblies and Pump Seal Coolers are missing from SLRAs Table 2.3.2-3.
Dominion did not attempt to retain the exact nomenclature for component types as in the first LRA. SLRA Table 2.3.2-3 lists Strainer body, Orifice, Valve body, Heat exchanger (seal cooler - housing) and Heat exchanger (seal cooler tube), which correspond to the LRA component types.
- 13. As compared to LRAs Table 2.3.2-5, it seems that Instrument Valve Assemblies and Sump Screens are missing from SLRAs Table 2.3.2-4.
Instrument valve assemblies are called Valve body. The sump screens are within the Recirculation Spray system. Section 2.3.2.4 System Evaluation Boundary says The screens/strainers associated with the containment sump that supply suction to the low-head safety injection pumps are evaluated with the recirculation spray system.
The information discussed in the audit clarified information that had been provided by the licensee on the docket and resolved the above observations.
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Scoping and Screening Results - Fire Protection For Surry Power Station, Units 1 and 2, the staff reviewed the subsequent license renewal application (SLRA); NUREG-1766, Safety Evaluation Report Related to License Renewal of North Anna Power Station, Unit 1 and 2, and Surry Power Station, Units 1 and 2, December 2002, ADAMS Package Accession No. ML030160853; SLRA drawings, Updated Final Safety Analysis Report (UFSAR), Sections 9.10 and 18.2.7, and the following fire protection current licensing basis (CLB), documents listed in Surry Power Station, Units 1 and 2 license condition 3.I:
Surry, Units 1 and 2. Issuance of Amendments 54 and 53 to Facility Operating Licenses DPR-32 and DPR-37 RE: License Conditions relating to completion of Facility Modification for Fire Protection and Operation and Surveillance Requirement, September 19, 1979, ADAMS Accession No. ML012500016.
Forwards review of addl info provided in 790809, 1113 & 800114 ltrs re fire protection program status of review also encl. Util should attempt to improve schedule to complete mods by 801101, May 29, 1980, ADAMS Accession No. ML18139A365.
Forwards summary of mods for resolution of open items re NRC proposed rule on min fire protection requirements. Evaluation of fire doors & hose stations & review status encl, October 9, 1980, ADAMS Accession No. ML18139A813.
Forwards Suppl 1 to 790919 fire protection safety evaluation, based on util 801029 & 31 ltrs. Mods re cable tray covers & fire barriers are not acceptable. Review status encl, December 18, 1980, ADAMS Accession No. ML18139A983.
Forwards Suppl 2 to evaluation of open items in 790919 fire protection safety evaluation.
items have been reviewed & are acceptable. List of remaining unresolved issues encl.,
February 13, 1981, ADAMS Accession No. ML18139B097.
Forwards safety evaluation re safe shutdown capability in event of fire.
Nonconformances listed. Preliminary design concept for providing alternate source of cooling water to charging pump coolers acceptable, December 4, 1981, ADAMS Package Accession No. ML120940154.
Surry, Units 1 and 2. Issuance of Amendments 77 and 78 to Facility Operating License DPR-32 and DPR-37 Re: Auxiliary Feedwater System, April 27, 1982, ADAMS Accession No. ML012830193.
Forwards supplemental SER addressing open items re App R, including approval of proposed mod concerning relocation of one charging pump, svc water pump &
respective water source. Facility in compliance w/App R requirements, November 18, 1982, ADAMS Accession No. ML18139C134.
Surry, Units 1 and 2. Issuance of Amendments 93 and 92 to Facility Operating Licenses DPR-32 and DPR-37 Re: Fire Protection Systems, January 17, 1984, ADAMS Accession No. ML012830219.
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Approval of technical exemption requests from Appendix R, 10 CFR Part 50 for Surry Power Station, February 25, 1988, ADAMS Accession No. ML012670091.
Forwards safety evaluation of revised post-fire safe shutdown methodology, July 23, 1992, ADAMS Accession No. ML18153D066.
Surry, Units 1 and 2. Issuance of Amendment 217 to Facility Operating Licenses DPR-32 and DPR-37 RE: Relocation of Fire Protection Requirements, December 16, 1998, ADAMS Accession No. ML012690528.
During its review, the staff evaluated the system functions described in the SLRA and UFSAR to verify that the applicant had not omitted from the scope of license renewal any components with intended functions delineated under Title 10 of the Code of Federal Regulations (10 CFR) 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant had not omitted any passive and long-lived components subject to an aging management review in accordance with the requirements of 10 CFR 54.21(a)(1).
For Surry Power Station, Units 1 and 2, the staff reviewed the SLRA: NUREG-1766; SLRA drawings; UFSAR, Sections 9.10 and 18.2.7, and the following fire protection CLB, documents listed in Surry Power Station, Units 1 and 2 License Condition 3.I.
During the audit the staff identified potential fire protection structures, systems, and components (SSCs) that may have been excluded from the scope of subsequent license renewal and an aging management review. These SSCs were not included in the license renewal boundaries appear to have fire protection intended functions required for compliance with 10 CFR 50.48, as stated in 10 CFR 54.4.
The staff held discussions with the applicant to verify whether the identified fire protection systems and components are within the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an aging management review in accordance with 10 CFR 54.21(a)(1). In cases where systems and components are not within the scope of license renewal and are not subject to an aging management review, the staff requested the applicant provide justification for the exclusion. A summary of the staffs review will be documented in the SER.
- 3. Supplement to the SLRA On April 2, 2019, Dominion Energy voluntary submitted a supplement to the SLRA (ADAMS Accession No. ML19095A666) on a total of 45 topics resulting from the discussions held during the in-office regulatory audit:
- 1.
Cracking of Cu >15% Zn for Water Treatment Valves
- 2.
Cracking of Cu >15% Zn for Fire Protection Spray Nozzles
- 3.
TLAA Clarification
- 4.
FER Section 3.2.2.2.9 Correction
- 5.
Recirculation Spray System Pump Suction Piping Note
- 6.
Containment Sump Pumps Material Clarification
- 7.
Manage FAC for Feedwater Heater Channel
- 8.
Program Management of Stainless Steel Crane Components
- 9.
Diesel Fire Pump Engine Component Clarification
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- 10. Loss of Material in Fiberglass Aging Management
- 11. Steam Generator Primary Inlet and Outlet Nozzle AMR Clarification
- 12. Addition of System and Component Specific Erosion
- 13. Heat Exchanger Tube Heat Transfer Function Clarification
- 14. Security Fuel Oil Tank and Piping Program Management Clarification
- 16. Leaching of Concrete in Structures
- 17. ASME Section XI, Subsection IWE program Clarifications - Containment Liner Boundary, Dissimilar Metal Welds, and Seals and Gaskets
- 18. Galvanized Steel Supports Clarification
- 19. Flood Barrier Intended Function in Miscellaneous Structural Commodities Clarification
- 20. Clarification of Flood Dike Components
- 21. Stainless Steel and Aluminum Structural Components
- 22. ASME Section XI, Subsection IWE program Exception Consistency Notes
- 23. Cracking of Titanium Valves in Raw Water in the Service Water System
- 24. Cast Austenitic Stainless Steel Control Rod Drive Mechanism Latch Housings
- 25. Alternate AC Diesel Generator Jacket Water Expansion Tank
- 28. Environmental-Assisted Fatigue: Update to Calculation
- 29. Crane Load Cycle Limits: Update to TLAA Evaluation Updated
- 30. Piping Subsurface Flaw Evaluations: Update to SLRA Table 4.7.5-1
- 31. Flow Accelerated Corrosion program (B2.1.8): Enhancement #1 Clarification
- 32. Bolting Integrity program (B2.1.9): Program Description and UFSAR Supplement Revisions
- 33. Open-Cycle Cooling Water System program (B2.1.11): Program Description Revision
- 34. Fire Water System program (B2.1.16): Enhancements Added/Clarified, Program Description and UFSAR Supplement Revisions
- 35. Fuel Oil Chemistry program (B2.1.18): Program Description, UFSAR Supplement, Exceptions, and Enhancements Revisions
- 36. Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.25): Program Description, UFSAR Supplement, and Enhancements Revisions
- 37. Buried and Underground Piping and Tanks program (B2.1.27): Enhancement 2 completed, Enhancement 3 Clarified, and UFSAR Supplement Revisions
- 38. Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program (B2.1.28): Program Description, UFSAR Supplement and Enhancements Revisions; Exceptions and Enhancements Additions
- 39. ASME Section XI, Subsection IWE program (B2.1.29): Enhancement Revision and Exception Addition
- 40. ASME Section XI, Subsection IWF program (B2.1.31): Enhancement Addition
- 41. Structures Monitoring program (B2.1.34): Program Description, UFSAR Supplement and Enhancements Revised; Enhancements Added
- 42. Protective Coating Monitoring and Maintenance program (B2.1.36): Program Description Revision
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- 43. Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program (B2.1.39): Program Description Revision and Enhancement Addition
Gap Analysis Tables Clarified/Revised
- 45. Leak-Before-Break, Update to SLRA Section 4.7.3
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- 4. Applicant Personnel Contacted During Audit Name Affiliation Paul Aitken Dominion Energy Eric Blocher Dominion Energy Craig Heah Dominion Energy Richard Eagan Dominion Energy Steven Williams Dominion Energy Charles Tomes Dominion Energy Beth Haluska Dominion Energy Viki Armentrout Dominion Energy Brian Mount Dominion Energy Tom Snow Dominion Energy Gregory Travers Dominion Energy John Thomas Dominion Energy Patrick Nelson Dominion Energy Keith Miller Dominion Energy Daniel Madden Dominion Energy John Disosway Dominion Energy Patrick Nelson Dominion Energy James Zaborowski Dominion Energy Joshua Bell Dominion Energy Bryan McCarter Dominion Energy Ronald Burner Dominion Energy Bret Rickert Dominion Energy Michael Carter Dominion Energy Mark Rinckel Framatome Ashok Nana Framatome Ryan Hosler Framatome Benjamin Leber Westinghouse Eric Johnson Westinghouse Benjamin Mays Westinghouse Thomas Zalewski Westinghouse