ML19163A396

SLRA Email Transmittal of Draft RAIs with Attachments - June 11, 2019

ML19163A396
Person / Time
Site:	Surry
Issue date:	06/11/2019
From:	Sayoc E NRC/NRR/DMLR/MRPB
To:	Aitken P, Blocher E Dominion Energy, Virginia Electric & Power Co (VEPCO)
Sayoc E, NRR-DMLR 301-287-3716
References
Download: ML19163A396 (4)

Text

From: Sayoc, Emmanuel To: Paul Aitken; Eric A Blocher Cc: Wu, Angela

Subject:

Draft RAI Surry TRP 20 Open Cycle Cooling Water Date: Tuesday, June 11, 2019 10:23:00 AM Attachments: 020 Surry OCCW RAI Gavula Johnson.docx Paul, Eric, I am hoping this is the last RAI. Do you need a clarification call?

Emmanuel Manny Sayoc Safety Project Manager NRR/DLR 301-415-4084

Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As provided in §54.29(a), a renewed license may be issued if the staff finds that actions have been identified, which either have been or will be taken, with respect to managing the effects of aging during the period of extended operation.

As described in the Standard Review Plan for Subsequent License Renewal (SLR), an applicant may reference the GALL-SLR Report in a subsequent license renewal application (SLRA) to designate which aging management programs will be used and how they correspond to the programs in the GALL-SLR Report. If an applicant takes credit for a program in the GALL-SLR Report, it is incumbent on the applicant to ensure the conditions and operating experience at the plant are bounded by those for which the GALL-SLR Report aging management program (AMP) was evaluated. To complete its review and enable the formulation of a finding under §54.29(a),

the staff requires additional information regarding the matters described below.

RAI B2.1.11-1 Generic Letter 89-13 Commitments Background. GALL-SLR AMP XI.M20, Open-Cycle Cooling Water System, states that the inspection scope, methods, and frequencies are in accordance with the applicants docketed response to Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Components. SLRA Section B2.1.11, Open-Cycle Cooling Water System, states that the program is an existing program that, following enhancement, will be consistent with the GALL-SLR AMP XI.M20. SLRA Section B2.1.11 also states that periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers is performed in accordance with the site commitments to GL 89-13.

ETE-SLR-2018-1314, Aging Management Program Evaluation Report - Open-Cycle Cooling Water System, Revision 2, documents and evaluates the activities in the associated AMP that are credited for managing aging as part of Surrys SLRA. ETE-SLR-2018-1314 discusses a discrepancy between Surrys response to GL 89-13 (letter dated October 2, 1991 (89-572G))

and the maintenance strategy implementation for the charging pump lube oil coolers. The maintenance strategy changed from periodic replacement of charging pump lube oil coolers to performing routine inspection and maintenance. ETE-SLR-2018-1314 states that the discrepancy was evaluated in accordance with the commitment change evaluation process and cites corrective action CA3022000 Submit Commitment Change Paperwork to Update Requirements for Charging Pump LO [Lube Oil] Coolers (March 9, 2017). The staff noted that the change in maintenance strategy affected the scope of Surrys Open-Cycle Cooling Water System program, because components that are periodically replaced are excluded from the scope of an aging management review for license renewal.

In response to staff questions for CA3022000, Surry posted condition report CR1091365, (March 6, 2018) A Commitment Change Evaluation Was Completed and Approved Mistakenly.

The condition report states that the commitment change evaluation was for a change made to a response to the NRC, not a commitment to the NRC. The actions discussed in the condition report included a clarification regarding the difference between a response and a commitment to the NRC.

During its review of ER-SU-5314, Generic Letter 89-13 Program, Revision 2, the staff noted that Attachment 1, Generic Letter 89-13 Components and Commitments, includes a table for each set of components in the program and includes a column labeled Commitment Source.

Every set of components in the list includes Letter to NRC 10/2/91 Serial Number 89-572G as

the source of the commitment to perform the specified GL 89-13 activity. However, the tables initial note states that the letter dated April 30, 1991 (Serial 89-572E), summarized the GL 89-13 program and that the response was updated by letter dated October 2, 1991 (Serial 89-572G),

which supersedes Serial Number 89-572E. No new commitments were made.

The staff notes that the letter dated April 30, 1991 (Serial 89-572E), states that a detailed revision of [Surrys] initial January 29, 1990, response incorporating the subsequent supplements and the additions integrated into this summary description will be separately forwarded. In addition, the staff notes that none of the GL 89-13 response letters appear to specifically identify the sites activities for periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers as being commitments.

Issue. Because none of the sites GL 89-13 response letters appear to specifically identify the commitments for periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers, the staff was unable to verify that the Open-Cycle Cooling Water System program would be performed in accordance with the sites commitments to GL 89-13. The program documentation appears to cite the letter dated October 2, 1991 (89-572G), as the source of the sites GL 89-13 commitments. However, the recent condition report (CR1091365) states that because the information in the October 2, 1991, letter was only a response to GL 89-13 and not a commitment, there was no need to perform a commitment change evaluation for changing the approach discussed in the October 2, 1991, letter. Based on the position discussed in CR1091365, the staff is unsure of the sites GL 89-13 commitments.

Request. Provide additional information to clarify the sites GL 89-13 commitments. Include information about which prior GL 89-13 response letter(s) to the NRC contain(s) the commitments that are discussed in SLRA Section B2.1.11. If the source of Surrys commitments to GL 89-13 are not from the response dated October 2, 1991 (89-572G), also include information regarding the circumstances about why ER-SU-5314, Generic Letter 89-13 Program, Revision 2, cites the letter dated October 2, 1991 (89-572G).

RAI B2.1.11-2 AMR Items for Open-Cycle Cooling Water System Background. SLRA Section B2.1.11, Open-Cycle Cooling Water System, states that periodic heat transfer testing, visual inspection, and cleaning of heat exchangers are performed in accordance with the site commitments to GL 89-13 to verify heat transfer capabilities. SLRA Section B2.1.11 also includes an enhancement to the monitoring and trending program element to revise procedures to require trending the inspection results of the emergency service water pump engine heat exchangers.

The staff notes that ER-SU-5314, Generic Letter 89-13 Program, Revision 2, includes the emergency service water pump engine heat exchanger and specifies associated activities for periodic heat transfer testing, as well as inspection and maintenance. In addition, ER-SU-5314 includes the emergency service water pump angle drive and specifies that heat transfer is checked during monthly surveillance testing, and that cooling water flow is verified during inspection and maintenance activities.

Although SLRA Table 3.3.2-4 Service Water - Aging Management Evaluation, includes other emergency service water pump components, it does not appear to include the emergency service water pump engine heat exchanger or the emergency service water pump angle drive.

Issue. Although SLRA Section B2.1.11 includes an enhancement to trend inspection results associated with emergency service water pump engine heat exchangers, the SLRA does not appear to include a corresponding aging management review item(s). In addition, although Surrys GL 89-13 program appears to specify activities to address heat transfer for the emergency service water pump angle drive, the SLRA does not appear to include a corresponding aging management review item.

Request. For the emergency service water pump engine heat exchangers and the emergency service water pump angle drives, provide information showing that assessment of the heat transfer capabilities of safety-related heat exchangers (with a heat transfer intended function) will be performed by the SLRA Section B2.1.11, Open-Cycle Cooling Water System program, in accordance with site commitments to GL 89-13. Include information showing either 1) that existing aging management review items with corresponding aging effects are included in the SLRA for these components or 2) that aging management review items are not needed for these components, to demonstrate that the effects of aging will be adequately managed.