ML19169A329

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Report for the Site Regulatory Audit Regarding the Subsequent License Renewal Application Review (EPID Nos. L-2018-RNW-0023 and L-2018-RNW-0024)
ML19169A329
Person / Time
Site: Surry  Dominion icon.png
Issue date: 06/20/2019
From: Sayoc E
NRC/NRR/DMLR/MRPB
To: Stoddard D
Dominion Energy Virginia, Virginia Electric & Power Co (VEPCO)
Wu A, 415-2995
References
EPID L-2018-RNW-0023, EPID L-2018-RNW-0024
Download: ML19169A329 (23)


Text

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June 20, 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, UNIT NOS. 1 AND 2 - REPORT FOR THE ON-SITE 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), April 2, 2019 (ADAMS Accession No. ML19095A666),

and June 10, 2019 (ADAMS Accession No. ML19168A028), 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 staff of the U.S. Nuclear Regulatory Commission (NRC) completed an on-site regulatory audit from April 22-25, 2019, in accordance with the on-site regulatory audit plan (ADAMS Accession No. ML19098A810). 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 Projects 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

ML19169A329 *via e-mail OFFICE PM:MRPB:DMLR PM:MRPB:DMLR LA:MRPB:DMLR BC:MRPB:DMLR PM:MRPB:DMLR NAME AWu ESayoc* YEdmonds EOesterle* ESayoc DATE 6/10/19 6/18/19 6/19/19 6/18/19 6/20/19

Audit Report On-Site Regulatory Audit Surry Power Station, Unit Nos. 1 and 2, Subsequent License Renewal Application April 22 - 25, 2019 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF MATERIALS AND LICENSE RENEWAL Docket Nos: 50-280 and 50-281 License Nos: DPR-32 and DPR-37 Licensee: Virginia Electric and Power Company (Dominion Energy Virginia)

Facility: Surry Power Station, Unit Nos. 1 and 2 Location: Innsbrook, Virginia Surry, Virginia Dates: April 22-25, 2019 Reviewers: E. Sayoc, Project Manager, DMLR B. Rogers, Senior Project Manager, DMLR B. Wittick, Branch Chief, DE A. Buford, Structural Engineer, DE A. Prinaris, Structural Engineer, DE W. Holston, Sr. Mechanical Engineer, DMLR A. Huynh, Mechanical Engineer, DMLR G. Thomas, Structural Engineer, DE S. Ray, Senior Electrical Engineer, DE M. McConnell, Senior Electrical Engineer, DE M. Yoo, Materials Engineer, DMLR A. Chereskin, Chemical Engineer, DMLR S. Krepel, Nuclear Engineer, DSS

Report for the On-Site Regulatory Audit Regarding the Surry Power Station, Unit Nos. 1 and 2 Subsequent License Renewal Application

1. Introduction The U.S. Nuclear Regulatory Commission (NRC or the staff) conducted an in-office audit of the Virginia Electric and Power Company (Dominion Energy Virginia or the applicants) (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).

This regulatory audit is a follow-up from the in-office regulatory conducted between February 4 -

February 28, 2019. The scope of this audit focuses on areas where the NRC staff needed to observe, walkdown, or verify site information to conclude the scoping and screening methodology audit, or AMP, AMR, and TLAA audit. The specific areas of focus during the audit are provided below:

  • SLRA AMP B2.1.16, Fire Water System
  • SLRA AMP B2.1.17, Outdoor and Large Atmospheric Metallic Storage Tanks
  • SLRA AMP B3.3, Environmental Qualification of Electric Equipment, SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment
  • 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 and Loss of Fracture Toughness of Reactor Vessel Support Steel
2. Audit Activities The following sections discuss the areas reviewed by the staff.

SLRA AMP B2.1.16, Fire Water System Audit Activities. During its audit, the staff conducted walkdowns of the 1A and 1B fire protection/domestic water storage tank (FWST). In addition, the staff interviewed Dominions staff and reviewed onsite documentation provided by Dominion.

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 NA In-Service Internal Tank Inspection Report 01-FP- Revision 0 TK-1A

Document Title Revision /

Date NA In-Service Internal Tank Inspection Report 01-FP- Revision 0 TK-1B 1113848 Condition Report (CR): Fire Protection Tank 1A 01/11/2019 Foundation and Coating Degradation 1113856 CR: Fire Protection Tank 1B Foundation and 01/11/2019 Coating Degradation 1121793 Engineering documentation of assessment of 04/25/2019 undermining of 1-FP-TK-1A and 1B 38103851700 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel 03/01/2019 Engine Driven Fire Pump]

38103758472 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel 03/25/2018 Engine Driven Fire Pump]

38103679516 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel 12/29/2016 Engine Driven Fire Pump]

38103570743 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel 12/31/2015 Engine Driven Fire Pump]

38103457968 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel 12/28/2014 Engine Driven Fire Pump]

38102396326 Investigate/Repair underground leak on fire 09/08/2008 protection header near 1-FP-381 38103115596 Repair/Replace hydrant 02/11/2014 38103256391 Repair leak associated with 1-FP-1025 [in the 12/27/2012 vicinity of 1-FP-1024]

38103115596 Repair/replace Hydrant 02/15/2013 NA Sprinkler Operating Experience Summary 05/11/2019 NA Main Drain Operating Experience Summary 05/10/2019 497373 Sprinkler head failed 11/21/2012 The staff made the following observation during walkdowns:

  • During the walkdown of the 1A and 1B FWST, the staff noted that the tank ring foundation has a recessed area between the tank and the inner diameter of the

foundation. In some locations, this ring was filled with dirt and in others filled with vegetation.

The staff made the following observations during the audit:

  • The staff reviewed the In-Service Internal Tank Inspection Reports for the FWSTs, 01-FP-TK-1A and 01-FP-TK-1B, and noted that:

(a) the 2019 inspections consisted of taking tank bottom UT thickness measurements in approximately 87,000 locations for 01-FP-TK-1A and 84,000 locations for 01-FP-TK-1B; (b) the scanned area included the tank bottom and bottom course of the tank shell; (c) the nominal thickness for the bottom plates is 0.3125 inches; (d) the lowest observed thickness reading of the tank bottom plates for 01-FP-TK-1A was 0.2120 inches and 0.2388 inches for 01-FP-TK-1B; (e) an extreme value analysis was conducted, which resulted in predicted minimum thicknesses of 0.2111 inches for 01-FP-TK-1A and 0.2203 inches for 01-FP-TK-1B.

The reports also stated that it detected laminations in the tank bottom plates but not in the bottom course of the tank shell. The report concluded that the previous tank measurements did not account for the fact that there were laminations and recorded the thickness of the top lamination layer and not the entire thickness of the tank bottom plates. The 2019 inspection was able to replicate the lamination data in at least one location for 01-FP-TK-1A based on a review of the thickness results from the 2008 and 2014 inspections as compared to the measured thickness of the lamination in 2019.

The minimum wall thickness measurement for the bottom course of the tank shell was 0.2550 inches for 01-FP-TK-1A and 0.3650 inches for 01-FP-TK-1B. The minimum wall thickness required is 0.115 inches.

Using the predicted minimum thickness value, the tanks have a projected useful remaining life of 55 years for 01-FP-TK-1A and 66 years for 01-FP-TK-1B.

  • The staff reviewed CR 1121793 and noted that Dominion stated the following:

Civil Engineering has inspected the foundation for the tanks. There is no evidence of on-going erosion of the soil beneath the tank that would indicate significant undermining is occurring. Therefore, there are no immediate concerns for the structural stability of the tanks. Civil Engineering recommends replacing the missing material to prevent further degradation.

During the audit, it was stated that a new AMR item would be added to the SLRA Tables 3.5.2-X and an enhancement to the Structures Monitoring program.

Pending review by the staff, these changes will eliminate the need for an RAI.

  • The staff reviewed the below work orders (WO) and noted the following regarding testing of the fire pumps [gallons per minute (gpm), total dynamic head (TDH), pounds per square inch differential (psid)]:

Diesel Driven Pump Year 2500 gpm TDH, psid 3050 gpm TDH, psid WO 2019 113 106 38103851700 2018 115 107 38103756472 2016 113.5 107.5 38103679516 2015 113.5 106 38103570743 2014 114 108 38103457968 Motor Driven Pump Year 2500 gpm TDH, psid 3050 gpm TDH, psid WO 2019 117 98 38103851700 2018 116 116 38103758472 2016 112.8 91.6 38103679516 2015 116.4 117 38103570743 2014 116 91 38103457968 For the diesel driven pump tests the variability of the TDH results at both the 2500 and 3050 gallons per minute test runs were not indicative of an increase in flow blockage in the fire main piping. For the motor driven pump tests there were two anomalous results, which were preceded and followed by lower system pressure and therefore not indicative of an increase in flow blockage in the fire main piping.

  • The staff reviewed WO 38102396326, associated with Condition Report (CR) 105806 and noted that the repair consisted of replacing a gasket and tightening bolting.
  • The staff reviewed WO 038103256391 associated with CR 474655 and noted that the repair consisted of replacing a gasket, O-ring, and fasteners.
  • The staff reviewed WO 38103115596 associated with CR 504380 and noted that the repair consisted of replacing a hydrant and two isolation valves. The hydrant and valve degradation were not associated with the pressure boundary (e.g., stem damage).
  • The staff reviewed the Sprinkler Operating Experience Summary and noted the following:

Condition Year Brief Description Summary of Conditions Report Number 002099 2006 A sprinkler head at the west Sprinkler was replaced with end of the Unit 2 condenser the minor maintenance was found to be leaking at process and no work order 40 drops per minute (dpm). generated.

The work order was cancelled.

007510 2007 A sprinkler head in the Heating unit in the building laundry building was found failed, which allowed ice to to be spraying a fine mist. build up on the sprinkler Closed to a work order. head. This is event driven, not aging.

485731 2012 Corrosion was detected on a A walkdown was conducted sprinkler in the chemistry and the sprinkler head was primary hot lab. No follow- determined to be functional.

on information was provided.

496505 2012 A sprinkler head in the CRs documented the same turbine building was found to condition adverse to quality.

be leaking at 10 dpm. A Leakage occurred due to a subsequent condition report, broken fuse, not an aging 497330, stated that the leak effect. Significant outage had increased to 2 dps. A work was being conducted follow-on inspection noted in the vicinity when the that the fuse was missing. damage occurred.

497330 2012 A sprinkler head was found to be leaking in the Unit 2 turbine building at 2 dps. A follow-on inspection noted that the fuse was missing.

497373 2012 Sprinkler head failed, previously leaking at 10 dpm.

503979 2013 A Unit 2 turbine building Sprinkler head fuse sprinkler head was found to assembly was missing. Not be spraying water. A follow- an aging issue.

on inspection noted that the fuse was missing.

1080715 2017 A sprinkler head above the WO documented that Unit 2 air ejector failed. No sprinkler head internals

[1080728 follow-on information was were missing. Not an aging was a provided. effect.

possible typo in the Operating Experience Audit Report]

  • The staff reviewed the Main Drain Operating Experience Summary and noted the following:

Condition Year Brief Description Summary of Conditions Report Number 380377 2010 The sensing line upstream of a The plugged line was a 3/8-inch main drain gauge isolation valve test connection at the end of the is clogged as evidenced by the header resulting in a collection static and dynamic pressure point for rust. The function of reading being the same. the downstream sprinklers was never affected.

393845 2010 A drain on Unit 1 south side The test connection is a tee off turbine building is clogged. A of the main header and based subsequent condition report, on configuration it is a low point 398027 (10/06/2010), confirmed where rust debris could that blockage was not accumulate. The test line was downstream of the drain valve. not functional until the line was cleared; however, the function of the downstream sprinklers was never affected.

398027 2010 Approximately one inch of rusty The test connection is a tee off debris blocked line of the main header and based on configuration it is a low point where rust debris could accumulate. The test line was not functional until the line was cleared; however, the function of the downstream sprinklers was never affected.

Condition Year Brief Description Summary of Conditions Report Number 463714 2012 Approximately one inch of rusty The test connection is a tee off debris blocked line of the main header and based on configuration it is a low point where rust debris could accumulate. The test line was not functional until the line was cleared; however, the function of the downstream sprinklers was never affected.

496837 2012 The strainer downstream of an The strainers were replaced inspector test valve is clogged because they were constructed with debris and damaged of too fine of a mesh for use beyond repair. with well water applications.

1044047 2016 Clogged fire water line. The blockage occurred because the vent line weldolet was not installed correctly and the corrective action was to drill through the piping/weldolet to allow flow when required.

SLRA AMP B2.1.17, Outdoor and Large Atmospheric Metallic Storage Tanks Audit Activities. During its audit, the staff conducted walkdowns of the fire protection/domestic water storage tanks, refueling water storage tank, chemical addition tanks, emergency condensate storage tanks, and the emergency condensate makeup tanks. In addition, the staff interviewed Dominions staff.

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 11448-FC-12A Miscellaneous Foundations (Refueling Water 07/27/1988 Storage, Condensate Storage, and Chemical Addition Tanks) 11448-FC-12B 110,000 Gallon Condensate Storage Tank Drawing 09/28/1993 CR1121803 Water identified by one of 13 weep holes on 01-CN- 04/25/2019 TK-1 Emergency Condensate Storage Tank

Document Title Revision /

Date CR1121772 Water identified by one of 13 weep holes on 02-CN- 04/25/2019 TK-1 Emergency Condensate Storage Tank The staff made the following observations during walkdowns:

  • During the walkdown of the refueling water storage tank (RWST), the staff noted that it is insulated with corrugated aluminum with overlapping seams and rests on a concrete foundation filled with an oil sand cushion. The staff also noted that the caulking used at the concrete-component interface of the RWST was degraded and was missing along some sections.
  • During the walkdown of the emergency condensate storage tanks (ECSTs) the staff noted that condensation was present on just one of the drainage weep holes for each of the concrete missile barriers. The plant staff proposed that the source of condensation was leaks through a plug on the roof of each of the missile shield barriers. The duration and extent of leakage through the plug is unknown. The ECSTs are contained within the missile shield barriers with insulation between the concrete and tank sides, and any leakage that penetrates the insulation to the surface of the tank could be retained for an extended period of time, potentially corroding the external surface of the tank.

The staff will consider issuing an RAI based on the staffs walkdown. The staff will document its evaluation of this potential RAI in the SER.

SLRA AMP B2.1.30, ASME Section XI, Subsection IWL Audit Activities. During its audit, the staff conducted walkdowns of the external faces of SPS twin containments. In addition, the staff interviewed Dominions staff and reviewed onsite documentation provided by Dominion.

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 Inspection Report Visual Examination of IWL - Inspection Results and 6/22/17 under Associated Work Orders ER-AA-NDE-VT-606 ETE-SU-2013- Unit 1 Containment Repair Plan and Evaluation 08/09/2014 0031

Document Title Revision /

Date ETE-SU-2017- Unit 2 Containment IWL Inspections Summary and 08/14/2017 0051 Evaluation ET-NPD-S Containment Concrete Structure Void Area Repair 10/03/2003 0231 ET-S-03-0107 Containment Concrete Structure Void Area Repair Revision 1, 05/19/2003 ET-S-06-0136 02-BS-BLD-CONT-BLDG Containment Structure 01/24/2007 Repair Plan & Evaluation ET-S-03-0107 Containment Concrete Structure Void Area Repair Revision 1, 05/19/2003 The staff made the following observation during the audit:

  • The staff reviewed documentation listed above and interviewed applicants staff and verified that areas found to have embedded wood were adequately evaluated and dispositioned. The staff also found that based on its audit of the applicants inspection documentation, IWL evaluations, needed repairs to date, and conclusion that the identification of small pieces of embedded wood does not impact the structural integrity, design function, or ability of the containment structures to perform their intended functions.

SLRA AMP B2.1.31, ASME Section XI, Subsection IWF Audit Activities. During its audit, the staff interviewed Surry Power Station onsite staff and reviewed onsite documentation provided by Dominion.

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 CR1005646 U-2 Neutron Shield Tank level is Lowering August 07, 2015 CR479576 Neutron Shield Tank Detector Well Leakage, Unit 2 June 21, 2012 (Proprietary)

NCRODP Neutron Shield Tank Cooling Water Subsystem - May 10, 2004 S Figure 60-3-S 11448-FM- Reactor Support and Neutron Shield Tank Drilling Revision 6 109A Template - SH1

11448-FM- Reactor Support and Neutron Shield Tank Drilling Revision 7 109B Template - SH2 11448-FV-7D Reactor Neutron Shield Tank, Surry Power Station - Revision 8

[Unit 1]

11448-FV-7M Reactor Neutron Shield Tank, Surry Power Station - Revision 5

[Unit 1]

11448-FV-7G Reactor Neutron Shield Tank, Surry Power Station - Revision 4

[Unit 1]

11548-FV-7D Reactor Neutron Shield Tank, Surry Power Station - Revision 4

[Unit 2]

11548-FV-7F Reactor Neutron Shield Tank Sheet 5, 1972 Extension Revision 3

[Unit 2]

NUS-380 Specification for Installation of Reactor Vessel for 06/01/1971 Surry Power Station, 1972 Extension - Surry Power Station NUS-96 Fabrication of Neutron Shield Tank for Surry Power 09/20/1968 Station, 1972 Extension - Surry Power Station NUS-368 Instructions for Installation of the Neutron Shield Tank 03/17/1970 CEM-0142 Sensitivity Evaluation of the Structural Adequacy of the Revision 1 Reactor Vessel Sliding Foot Assemblies for the Loss of April 30, 2015 Multiple Cap Screws ETE-SU- RV Support Sliding Foot Assembly Cap Screws Revision 0 2015-0006 Evaluation for Elimination May 19, 2015 N/A Additional IWF Questions April 29, 2019 CR579397 Spring Can Hanger not within +/- 10% of the Design May 11, 2015 Setting [Unit 1]

0-MCM-1026- Mechanical Corrective Maintenance Procedure: Spring Revision 4 01 Hanger Pipe Support Blocking and Unblocking [Units 1&2]

CR025102 VT-3 Rejection on Hanger 19 at Blow Down Line 3- November 16, WGCB-1-601 [Unit 1] 2007 CR002512 ASME Support 2-CH-H004A [Unit 2] October 15, 2006

CR547325 CR: Bolt Heads on Inner Bolts not Tight to Side Clamp CR May 05, 2014 and on Support 2-WS-H002B (Unit 2); CA: Engineering CA May 12, 2014 CA282300 Evaluation SLRA Enclosure 1, SLRA Supplement Topic 40: B2.1.31 April 2, 2019 Change ASME Section XI, Subsection IWF: Enhancement Notice 2 Addition and Enclosure 2, ASME Section XI, Subsection IWF Subsequent License Renewal Commitment Addition.

The staff made the following observation(s) during the audit:

  • The applicant voluntarily enhanced SLRA Section B2.1.31, as noted in SLRA Change Notice 2, to address a monitoring and trending program element deficiency identified by NRC staff during the In-Office Audit Session to increase/modify the sample size if a component support does not exceed the acceptance standards of IWF-3400 but is electively repaired to as-new condition.
  • As noted in Additional IWF Questions, the NST is not a pressure vessel under the ASME Code jurisdiction. The applicant confirmed that ASME Code Section XI, Subsection IWF, jurisdiction includes the reactor vessel support sliding feet assemblies but not the Neutron Shield Tank (NST).
  • In accordance with SPEC NUS 096, the entire NST is stress relieved except for the final weld joining the two sections of the skirt. Peening unless approved by engineers was not permitted. All welds are 100 percent radiographed and checked by dye penetrant or magnetic particles. The tank was tested until no leaks were detectable.

The staff will consider issuing RAIs based on the staffs onsite interviews or review of onsite documentation. The staff will document its evaluation of this/these potential RAI(s) in the SER.

SLRA AMP B3.3, Environmental Qualification of Electric Equipment and TLAA Section 4.4, Environmental Qualification of Electric Equipment Audit Activities. During its onsite audit, the staff interviewed Dominions staff and reviewed onsite documentation provided by Dominion to ascertain how the licensee addressed interfaces between mechanical and electrical equipment for the Surry environmental qualification program.

Specifically, the staff reviewed the licensees qualification evaluation of electric equipment such as motor operated valves, transmitters, and solenoid valves to ensure that the environmental effects of mechanical components like gaskets, seals, lubricants and connections were addressed with respect to subsequent license renewal.

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 CT-EQUAL-000- N/A - plant qualification evaluation for Limitorque Revision 0 PQE-03.02-P01 Motor Operated Valve, inside containment ETE-CEP-2011- Acceptability of MOV Long Life NLGI Grade 0 Revision 0 0007 Grease in Limitorque Actuatuors ET-CEP-02-0015 Justification and Implementation Plan for the use of Revision 2 MOV Long Life Grade 1 Grease for North Anna and Surry Power Stations - Units 1 and 2 SU-EQUAL-000- N/A - plant qualification evaluation for Reliance Revision 1 PQE-04.06-P01 motor, specifically for charging pump component cooling water pump motor CT-EQUAL-000- N/A - plant qualification evaluation for Limitorque Revision 2 PQE-03.01-P01 Motor Operated Valves, outside containment CT-EQUAL-000- N/A - plant qualification evaluation for Rosemount Revision 0 PQE-08.03-P01 pressure transmitter 1153 Series D CT-EQUAL-000- N/A - plant qualification evaluation for Rosemount Revision 0 PQE-08.04-P01 pressure transmitter 1153 Series B CT-EQUAL-000- General qualification evaluation for Limitorqe Motor Revision 2 GQE-03.01-G01 Operator NUGEQ Report Clarification of Information Related to the August 1989 Environmental Qualification of Limitorque Motorized Valve Operators CT-EQUAL-000- N/A - plant qualification evaluation for neutron flux Revision 0 PQE-08.16-P01 monitoring system CT-EQUAL-000- N/A - plant qualification evaluation for Weed Series Revision 1 PQE-08.17-P02 612 Resistance Temperature Detector CT-EUAL-000- N/A - plant qualification evaluation for Automatic Revision 1 PQE-35.01-P01 Switch Company Solenoid Valves CT-EQUAL-000- N/A - plant qualification evaluation for Conax Revision 0 PQE-34.01- P01 conduit seal SU-EQUAL-000- N/A - plant qualification evaluation for Automatic Revision 0 PQE-35.07-P01 Valve Corporation Solenoid Valves

Document Title Revision /

Date CT-EQUAL-000- N/A - plant qualification evaluation for Target Rock Revision 1 PQE-35.04-P02 Solenoid Valves CT-EQUAL-000- N/A - plant qualification evaluation for NAMCO limit Revision 1 PQE-09.01-P01 switch, EA-180 series, manufactured during or after October 1986 CT-EQUAL-000- N/A - plant qualification evaluation for NAMCO limit Revision 0 PQE-09.01-P02 switch, EA-180 series, manufactured prior to and including October 1986 The staff made the following observation during the audit:

  • The staff reviewed the documents as cited in the Relevant Documents Reviewed table above and confirmed and verified that interfaces, including seals, lubricants and gaskets are addressed in the Surry environmental qualification program. Furthermore, staff verified that some lubricants are qualified separately while other lubricants are qualified with the equipment they serve. The plant qualification evaluations document replacement components and their respective replacement schedule as well as routine maintenance to maintain qualification (e.g., the replacement interval of an o-ring in a junction box seal is 10 years).

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 and Loss of Fracture Toughness of Reactor Vessel Support Steel Audit Activities. During its audit, the staff interviewed Dominions staff and reviewed onsite documentation provided by Dominion.

The table below lists the documents that were reviewed by the staff, in addition to those listed in the in-office audit report and were found relevant to the audit.

RELEVANT DOCUMENTS REVIEWED Document Title Revision /

Date Dominion - NRC SLR - Component Structural Configuration April 2019 Audit Presentation Dominion - NRC SLR - Mechanical Aging Management April 2019 Audit Presentation Dominion - NRC SLR - Supplemental Mechanical Slides April 2019 Audit Presentation Dominion - NRC SLR - Neutron Fluence and Gamma Dose / NST April 2019 Audit Presentation Analysis

Document Title Revision /

Date Dominion - NRC Irradiation Effects on Concrete & Steel April 2019 Audit Presentation LTR-REA-18-88 Surry Units 1 and 2 Concrete Fluence Analysis, Revision 2, Westinghouse Electric Company 04/08/2012 CH-93.400 Closed Cooling Water Chemistry Program, Revision 23 Procedure, Surry Power Station Unit Nos. 1 & 2 PVP2018-84786 Randy K. Nanstad et al., Some Useful Mechanical 07/15-20/2018 Property Correlations for Nuclear Reactor Pressure Vessel Steels, Proceedings of the ASME 2018 Pressure Vessels and Piping Conference, Prague, Czech Republic N/A Data Extracted from Surry Chemistry Database 4/18/2019 (Nuclear), Surry Unit 1 and Unit 2 Neutron Shield Tank Water Chemistry and Limits (since 2001) 11448-FM-1G Machine Location - Reactor Containment, Sections Revision 14 C-C & D-D, Surry Power Station Unit 1 11548-FV-7A Reactor Neutron Shield Tank Assembly, 1972 [Unit Revision 3 2] Surry Power Station 11548-FV-7B Reactor Neutron Shield Tank Sheet 1, 1972 Revision 4 Extension [Unit 2] Surry Power Station 11548-FV-7C Reactor Neutron Shield Tank Sheet 2, 1972 Revision 4 Extension [Unit 2] Surry Power Station 11548-FV-7D Reactor Neutron Shield Tank, Surry Power Station Revision 4

- Unit 1 11548-FV-7E Reactor Neutron Shield Tank Sheet 4, 1972 Revision 2 Extension [Unit 2] Surry Power Station 11548-FV-7F Reactor Neutron Shield Tank Sheet 5, 1972 Revision 3 Extension [Unit 2] Surry Power Station NUS-380 Specification for Installation of Reactor Vessel for 06/01/1971 Surry Power Station, 1972 Extension - Surry Power Station NUS-96 Fabrication of Neutron Shield Tank for Surry Power 09/20/1968 Station, 1972 Extension - Surry Power Station Revision

Document Title Revision /

Date NUS-368 Instructions for Installation of the Neutron Shield 03/17/1970 Tank NUS-5 Mixing and Delivering Structural Concrete for Surry 01/10/1969 Power Station, 1972 Extension - Surry Power Revision Station N/A Breakout Long Question 14 Revised (Chromate 04/23/2019 System OE discussion)

N/A RV Steel - Breakout Long Questions Revised 04/09/2019 N/A RV Steel - Breakout New Questions 1-4 04/24/2019 N/A RV Steel - Breakout Short Questions 1-4 04/08/2019 N/A RV Steel Supports - Document Excerpts 04/04/2019 CR479576 Neutron Shield Tank Detector Well Leakage, Unit 2 06/21/2012 (Proprietary)

CR494734 Neutron Shield Tank Detector Well Leakage 11/19/2012 CR099008 U2 Neutron Shield Tank in Action Level 1 for 05/14/2008 to Chlorides > 150 ppb 10/16/2008 CR1005646 U2 Neutron Shield Tank [Surge Tank] Level is 08/07/2015 Lowering CR358061 U2 Neutron Shield Tank Remains in Action Level 1 11/14/2009 for Chloride CA238320 CA to Engineering to Update the conclusion [...] that 06/25/2012 the Neutron Shield Tank Can Perform its Design Function with the Existing Minor Leaks 0-NSP-BS-005 Engineering Surveillance Procedure: Monitoring of Revision 11 Structures for SPS Units 1 & 2 ETE-SLR-2018- Review of Loads on Neutron Shield Tank for SPS Revision 0 1270 Units 1 & 2 Reactor Vessel Supports ETE-SLR-2018- Assessment of Radiation Effect on Reactor Vessel Revision 0 1271 Supports for SPS Units 1 & 2

Document Title Revision /

Date CM-AA-ETE-101, Condition Monitoring of Structures, SPS Units 1 & 2 Revision 7 Technical Report CE-0087 UFSAR 14.4-23 RPV Sliding Foot Support Analysis Revision 50.02 UFSAR Fig. 2.5-6 Response Spectra Design-Basis Earthquake Revision 47.04 DMR-SLR 1153 Document Modification Request: SLR-1603, SRP 4/24/2019 Section 3.5 - Containments, Structures, and Component Supports CEM-0142 Evaluation of Revised LOCA Loads for Surry Units Revision 1 1 and 2 RPV Sliding Foot Supports 4/30/2015 CE-1642 The Effect of Reactor Pressure Vessel (RPV) Head Revision 0 replacement on the RPV Support System (Neutron 5/27/03 Shield Tank), Surry Power Station Project Topical Unit No. 1 Surry Power Station - Life Extension 10/10/1986 Report (PTR) Evaluation of the Reactor Vessel Support 2178-1525314-B4 CE-1653 Review of Structural Adequacy of the Reactor 05/27/2003 Vessel Support Sliding Foot Assemblies, SPS Units 1&2 N/A Lubrite 2002 EPRI TR Irradiation Damage of the Concrete Biological May 2018 3002013051 Shield that Utilizes a Neutron Shield Tank - Basis for Concrete Biological Shield Wall for Aging Management EPRI TR Irradiation Damage of the Concrete Biological May 2018 3002011710 Shield- Basis for Evaluation of the Concrete Biological Shield Wall for Aging Management EPRI TR Structural Tools - Long Term Operations: December 2018 3002013084 Subsequent License Renewal Aging Effects for Structures and Structural Components (Excerpts)

The staff made the following observation(s) during the audit:

  • The revised SLRA does not address radiation streaming effects in areas of the Concrete Biological Shield (CBS) wall both above and below the neutron shield tank (NST) that are not shielded by water in the NST. The staffs audit of LTR-REA-18-88 referenced in SPS Report ETE-SLR-2018-1271 indicated that fluence estimates in these areas are significantly higher than the traditional beltline analysis in EPRI Report 3002013051 used as a basis in the submittal of the SLRA.
  • The SLRA identifies the External Surfaces Monitoring of Mechanical Components (SLRA Section B2.1.23) for loss of material of external NST surfaces and the Closed Treated Water Systems (SLRA Section B2.1.12) for loss of material of internal NST surfaces.

However, there is no SLRA aging management program (AMP) for management of aging effects for the NST as a component performing a structural support function for the reactor vessel.

  • The revised SLRA does not discuss any potential radiation effects on lubricants and coatings used for the sliding foot assemblies despite being widely discussed in the audited PTR. Loss of intended function(s) of lubricants and coating could potentially alter applied forces to the NST and impact its structural integrity. The SLRA does not provide for an AMR item for sliding foot assembly lubricants and coatings to manage the effects of aging due to radiation, if any, that could affect the sliding foot assemblies intended function(s).
  • The SLRA does not discuss loss of fracture toughness for the welded NST due to neutron embrittlement during the SPEO, even though reduction of fracture toughness and embrittlement due to radiation is discussed in the audited Stone & Webster PTR and ETE-SLR-2018-1271 reports. The SLRA does not provide a summary of the methodology used to calculate critical stresses with surface and through wall cracks and the key results.
  • The staff noted that the applicants documentation (Technical Report CE-0087) allows for a 10 percent reduction in cross sectional area of the NST steel. The revised SLRA does not discuss how the NST fluid chemistry will be controlled to minimize loss of material, so that the limiting values are not exceeded.
  • The staff noted several CRs indicating continuous leakage of the NST Unit 2 dating back to 1989, with no possible repairs. The SLRA does not provide a clear picture with continuous leakage how the shielding function of NST will be maintained during the subsequent period of extended operation (SPEO).

During the audit, the staff identified the following areas where additional information may be needed:

  • The effects of applied forces and reduction in steel cross sectional area (up to a 10 percent due to loss of material) in stress calculations for NST structural integrity assessment to the end of the SPEO.
  • How the structural integrity and structural support intended function of NST are to be managed during the SPEO. Discussion of an AMP and AMRs is lacking in the SLRA.
  • The methodology and models used for calculation of fluence/dose for areas of concrete bioshield (CBS) wall not shielded by the NST during the SPEO and determining limiting values for the CBS wall.
  • Managing the effects of concrete bioshield loss of strength in areas of concrete not shielded by the NST if limiting fluence/dose is determined to be over the SRP-SLR stated thresholds, or a summary of a structural evaluation providing basis that an AMP is not needed during the SPEO.
  • The methodology used for Fracture Mechanics Evaluation of steel NSTs, including that applied for welds and resulting HAZ evaluation due to radiation aging effects effects during the SPEO.
  • How the NST shielding function is maintained (i.e., how is NST ensured full of chromated fluid - or enough to fulfill its intended function) during the SPEO.
  • An apparent miss of AMRs for SCC for VascomaxTM maraging steel.
  • Potential radiation degradation/depletion of plant-specific used Lubrite resulting in the lubricant not performing its intended function in the sliding foot assembly shoes during the SPEO.
  • The capacity of Closed Treated Water Systems (CTWS) sampling AMP and fluid chemistry used to manage loss of material for NST during the SPEO. Information is needed regarding layers of defense on chromium layer on NST steel internal surface, OE indicating lack of corrosion, and effects of radiolysis on the NST fluid, if any.
  • Whether loss of material will materialize as an aging effect on the internal steel surfaces of NST to cause a 10 percent reduction in NST steel cross sectional area.
  • Operating Experience bases for SLRA statements that no OE due to irradiation has been identified in SMP nor in Further Evaluation for concrete and steel.
  • Whether plant-specific structural consequence analyses postulating losing any RV supports in SPS current licensing basis exists.

The staff will consider issuing RAIs on the above topics based on the staffs audit or review of onsite documentation. The staff will document its evaluation of these potential RAIs in the SER.

3. Applicant Personnel Contacted During Audit Name Affiliation Paul Aitken Dominion Eric Blocher Dominion Craig Heah Dominion Pat Nelson Dominion James Johnson Dominion

Name Affiliation Daniel Madden Dominion John Disosway Dominion Mark Pellegrino Dominion Joshua LaFrance Dominion John Lansing Dominion Ed Turko Dominion Brett Rickert Dominion Jim Stauffer Dominion Bridget Mix Dominion Brandon Logioco Dominion Kimberly Mitchell Dominion Candee Lovett Dominion Charles Tomes Dominion Brian Derreberry Dominion Keith Miller Dominion James Hester Dominion Greg Imbrogno Westinghouse

4. Exit Meeting An exit meeting was held with the applicant on April 25, 2019, to discuss the results of the regulatory on-site audit. The staff is considering the issuance of an RAI to support completion of the staffs SLRA review.