ML19169A329
| ML19169A329 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| 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
Enclosure 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 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:
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 B.2.1.30, ASME Section XI, Subsection IWL SLRA AMP B.2.1.31, ASME Section XI, Subsection IWF 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-TK-1A Revision 0 Document Title Revision /
Date NA In-Service Internal Tank Inspection Report 01-FP-TK-1B Revision 0 1113848 Condition Report (CR): Fire Protection Tank 1A Foundation and Coating Degradation 01/11/2019 1113856 CR: Fire Protection Tank 1B Foundation and Coating Degradation 01/11/2019 1121793 Engineering documentation of assessment of undermining of 1-FP-TK-1A and 1B 04/25/2019 38103851700 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel Engine Driven Fire Pump]
03/01/2019 38103758472 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel Engine Driven Fire Pump]
03/25/2018 38103679516 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel Engine Driven Fire Pump]
12/29/2016 38103570743 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel Engine Driven Fire Pump]
12/31/2015 38103457968 0-OPT-FP-008 Fire Pump Flow Rate Test [Diesel Engine Driven Fire Pump]
12/28/2014 38102396326 Investigate/Repair underground leak on fire protection header near 1-FP-381 09/08/2008 38103115596 Repair/Replace hydrant 02/11/2014 38103256391 Repair leak associated with 1-FP-1025 [in the vicinity of 1-FP-1024]
12/27/2012 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 Report Number Year Brief Description Summary of Conditions 002099 2006 A sprinkler head at the west end of the Unit 2 condenser was found to be leaking at 40 drops per minute (dpm).
The work order was cancelled.
Sprinkler was replaced with the minor maintenance process and no work order generated.
007510 2007 A sprinkler head in the laundry building was found to be spraying a fine mist.
Closed to a work order.
Heating unit in the building failed, which allowed ice to build up on the sprinkler head. This is event driven, not aging.
485731 2012 Corrosion was detected on a sprinkler in the chemistry primary hot lab. No follow-on information was provided.
A walkdown was conducted and the sprinkler head was determined to be functional.
496505 2012 A sprinkler head in the turbine building was found to be leaking at 10 dpm. A subsequent condition report, 497330, stated that the leak had increased to 2 dps. A follow-on inspection noted that the fuse was missing.
CRs documented the same condition adverse to quality.
Leakage occurred due to a broken fuse, not an aging effect. Significant outage work was being conducted in the vicinity when the 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 was found to be spraying water. A follow-on inspection noted that the fuse was missing.
Sprinkler head fuse assembly was missing. Not an aging issue.
1080715
[1080728 was a possible typo in the Operating Experience Audit Report]
2017 A sprinkler head above the Unit 2 air ejector failed. No follow-on information was provided.
WO documented that sprinkler head internals were missing. Not an aging effect.
The staff reviewed the Main Drain Operating Experience Summary and noted the following:
Condition Report Number Year Brief Description Summary of Conditions 380377 2010 The sensing line upstream of a main drain gauge isolation valve is clogged as evidenced by the static and dynamic pressure reading being the same.
The plugged line was a 3/8-inch test connection at the end of the header resulting in a collection point for rust. The function of the downstream sprinklers was never affected.
393845 2010 A drain on Unit 1 south side turbine building is clogged. A subsequent condition report, 398027 (10/06/2010), confirmed that blockage was not downstream of the drain valve.
The test connection is a tee off 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.
398027 2010 Approximately one inch of rusty debris blocked line The test connection is a tee off 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 Report Number Year Brief Description Summary of Conditions 463714 2012 Approximately one inch of rusty debris blocked line The test connection is a tee off 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 inspector test valve is clogged with debris and damaged beyond repair.
The strainers were replaced because they were constructed of too fine of a mesh for use 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 Storage, Condensate Storage, and Chemical Addition Tanks) 07/27/1988 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-TK-1 Emergency Condensate Storage Tank 04/25/2019 Document Title Revision /
Date CR1121772 Water identified by one of 13 weep holes on 02-CN-TK-1 Emergency Condensate Storage Tank 04/25/2019 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 under ER-AA-NDE-VT-606 Visual Examination of IWL - Inspection Results and Associated Work Orders 6/22/17 ETE-SU-2013-0031 Unit 1 Containment Repair Plan and Evaluation 08/09/2014 Document Title Revision /
Date ETE-SU-2017-0051 Unit 2 Containment IWL Inspections Summary and Evaluation 08/14/2017 ET-NPD-S 0231 Containment Concrete Structure Void Area Repair 10/03/2003 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 Repair Plan & Evaluation 01/24/2007 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 (Proprietary)
June 21, 2012 NCRODP S Neutron Shield Tank Cooling Water Subsystem -
Figure 60-3-S May 10, 2004 11448-FM-109A Reactor Support and Neutron Shield Tank Drilling Template - SH1 Revision 6 11448-FM-109B Reactor Support and Neutron Shield Tank Drilling Template - SH2 Revision 7 11448-FV-7D Reactor Neutron Shield Tank, Surry Power Station -
[Unit 1]
Revision 8 11448-FV-7M Reactor Neutron Shield Tank, Surry Power Station -
[Unit 1]
Revision 5 11448-FV-7G Reactor Neutron Shield Tank, Surry Power Station -
[Unit 1]
Revision 4 11548-FV-7D Reactor Neutron Shield Tank, Surry Power Station -
[Unit 2]
Revision 4 11548-FV-7F Reactor Neutron Shield Tank Sheet 5, 1972 Extension
[Unit 2]
Revision 3 NUS-380 Specification for Installation of Reactor Vessel for Surry Power Station, 1972 Extension - Surry Power Station 06/01/1971 NUS-96 Fabrication of Neutron Shield Tank for Surry Power Station, 1972 Extension - Surry Power Station 09/20/1968 NUS-368 Instructions for Installation of the Neutron Shield Tank 03/17/1970 CEM-0142 Sensitivity Evaluation of the Structural Adequacy of the Reactor Vessel Sliding Foot Assemblies for the Loss of Multiple Cap Screws Revision 1 April 30, 2015 ETE-SU-2015-0006 RV Support Sliding Foot Assembly Cap Screws Evaluation for Elimination Revision 0 May 19, 2015 N/A Additional IWF Questions April 29, 2019 CR579397 Spring Can Hanger not within +/- 10% of the Design Setting [Unit 1]
May 11, 2015 0-MCM-1026-01 Mechanical Corrective Maintenance Procedure: Spring Hanger Pipe Support Blocking and Unblocking [Units 1&2]
Revision 4 CR025102 VT-3 Rejection on Hanger 19 at Blow Down Line 3-WGCB-1-601 [Unit 1]
November 16, 2007 CR002512 ASME Support 2-CH-H004A [Unit 2]
October 15, 2006 CR547325 and CA282300 CR: Bolt Heads on Inner Bolts not Tight to Side Clamp on Support 2-WS-H002B (Unit 2); CA: Engineering Evaluation CR May 05, 2014 CA May 12, 2014 SLRA Change Notice 2, SLRA Supplement Topic 40: B2.1.31 ASME Section XI, Subsection IWF: Enhancement Addition and Enclosure 2, ASME Section XI, Subsection IWF Subsequent License Renewal Commitment Addition.
April 2, 2019 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-PQE-03.02-P01 N/A - plant qualification evaluation for Limitorque Motor Operated Valve, inside containment Revision 0 ETE-CEP-2011-0007 Acceptability of MOV Long Life NLGI Grade 0 Grease in Limitorque Actuatuors Revision 0 ET-CEP-02-0015 Justification and Implementation Plan for the use of MOV Long Life Grade 1 Grease for North Anna and Surry Power Stations - Units 1 and 2 Revision 2 SU-EQUAL-000-PQE-04.06-P01 N/A - plant qualification evaluation for Reliance motor, specifically for charging pump component cooling water pump motor Revision 1 CT-EQUAL-000-PQE-03.01-P01 N/A - plant qualification evaluation for Limitorque Motor Operated Valves, outside containment Revision 2 CT-EQUAL-000-PQE-08.03-P01 N/A - plant qualification evaluation for Rosemount pressure transmitter 1153 Series D Revision 0 CT-EQUAL-000-PQE-08.04-P01 N/A - plant qualification evaluation for Rosemount pressure transmitter 1153 Series B Revision 0 CT-EQUAL-000-GQE-03.01-G01 General qualification evaluation for Limitorqe Motor Operator Revision 2 NUGEQ Report Clarification of Information Related to the Environmental Qualification of Limitorque Motorized Valve Operators August 1989 CT-EQUAL-000-PQE-08.16-P01 N/A - plant qualification evaluation for neutron flux monitoring system Revision 0 CT-EQUAL-000-PQE-08.17-P02 N/A - plant qualification evaluation for Weed Series 612 Resistance Temperature Detector Revision 1 CT-EUAL-000-PQE-35.01-P01 N/A - plant qualification evaluation for Automatic Switch Company Solenoid Valves Revision 1 CT-EQUAL-000-PQE-34.01-P01 N/A - plant qualification evaluation for Conax conduit seal Revision 0 SU-EQUAL-000-PQE-35.07-P01 N/A - plant qualification evaluation for Automatic Valve Corporation Solenoid Valves Revision 0 Document Title Revision /
Date CT-EQUAL-000-PQE-35.04-P02 N/A - plant qualification evaluation for Target Rock Solenoid Valves Revision 1 CT-EQUAL-000-PQE-09.01-P01 N/A - plant qualification evaluation for NAMCO limit switch, EA-180 series, manufactured during or after October 1986 Revision 1 CT-EQUAL-000-PQE-09.01-P02 N/A - plant qualification evaluation for NAMCO limit switch, EA-180 series, manufactured prior to and including October 1986 Revision 0 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 Audit Presentation SLR - Component Structural Configuration April 2019 Dominion - NRC Audit Presentation SLR - Mechanical Aging Management April 2019 Dominion - NRC Audit Presentation SLR - Supplemental Mechanical Slides April 2019 Dominion - NRC Audit Presentation SLR - Neutron Fluence and Gamma Dose / NST Analysis April 2019 Document Title Revision /
Date Dominion - NRC Audit Presentation Irradiation Effects on Concrete & Steel April 2019 LTR-REA-18-88 Surry Units 1 and 2 Concrete Fluence Analysis, Westinghouse Electric Company Revision 2, 04/08/2012 CH-93.400 Closed Cooling Water Chemistry Program, Procedure, Surry Power Station Unit Nos. 1 & 2 Revision 23 PVP2018-84786 Randy K. Nanstad et al., Some Useful Mechanical Property Correlations for Nuclear Reactor Pressure Vessel Steels, Proceedings of the ASME 2018 Pressure Vessels and Piping Conference, Prague, Czech Republic 07/15-20/2018 N/A Data Extracted from Surry Chemistry Database (Nuclear), Surry Unit 1 and Unit 2 Neutron Shield Tank Water Chemistry and Limits (since 2001) 4/18/2019 11448-FM-1G Machine Location - Reactor Containment, Sections C-C & D-D, Surry Power Station Unit 1 Revision 14 11548-FV-7A Reactor Neutron Shield Tank Assembly, 1972 [Unit 2] Surry Power Station Revision 3 11548-FV-7B Reactor Neutron Shield Tank Sheet 1, 1972 Extension [Unit 2] Surry Power Station Revision 4 11548-FV-7C Reactor Neutron Shield Tank Sheet 2, 1972 Extension [Unit 2] Surry Power Station Revision 4 11548-FV-7D Reactor Neutron Shield Tank, Surry Power Station
- Unit 1 Revision 4 11548-FV-7E Reactor Neutron Shield Tank Sheet 4, 1972 Extension [Unit 2] Surry Power Station Revision 2 11548-FV-7F Reactor Neutron Shield Tank Sheet 5, 1972 Extension [Unit 2] Surry Power Station Revision 3 NUS-380 Specification for Installation of Reactor Vessel for Surry Power Station, 1972 Extension - Surry Power Station 06/01/1971 NUS-96 Fabrication of Neutron Shield Tank for Surry Power Station, 1972 Extension - Surry Power Station 09/20/1968 Revision Document Title Revision /
Date NUS-368 Instructions for Installation of the Neutron Shield Tank 03/17/1970 NUS-5 Mixing and Delivering Structural Concrete for Surry Power Station, 1972 Extension - Surry Power Station 01/10/1969 Revision N/A Breakout Long Question 14 Revised (Chromate System OE discussion) 04/23/2019 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 (Proprietary)
Neutron Shield Tank Detector Well Leakage, Unit 2 06/21/2012 CR494734 Neutron Shield Tank Detector Well Leakage 11/19/2012 CR099008 U2 Neutron Shield Tank in Action Level 1 for Chlorides > 150 ppb 05/14/2008 to 10/16/2008 CR1005646 U2 Neutron Shield Tank [Surge Tank] Level is Lowering 08/07/2015 CR358061 U2 Neutron Shield Tank Remains in Action Level 1 for Chloride 11/14/2009 CA238320 CA to Engineering to Update the conclusion [...] that the Neutron Shield Tank Can Perform its Design Function with the Existing Minor Leaks 06/25/2012 0-NSP-BS-005 Engineering Surveillance Procedure: Monitoring of Structures for SPS Units 1 & 2 Revision 11 ETE-SLR-2018-1270 Review of Loads on Neutron Shield Tank for SPS Units 1 & 2 Reactor Vessel Supports Revision 0 ETE-SLR-2018-1271 Assessment of Radiation Effect on Reactor Vessel Supports for SPS Units 1 & 2 Revision 0 Document Title Revision /
Date CM-AA-ETE-101, Technical Report CE-0087 Condition Monitoring of Structures, SPS Units 1 & 2 Revision 7 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 Section 3.5 - Containments, Structures, and Component Supports 4/24/2019 CEM-0142 Evaluation of Revised LOCA Loads for Surry Units 1 and 2 RPV Sliding Foot Supports Revision 1 4/30/2015 CE-1642 The Effect of Reactor Pressure Vessel (RPV) Head replacement on the RPV Support System (Neutron Shield Tank), Surry Power Station Revision 0 5/27/03 Project Topical Report (PTR) 2178-1525314-B4 Unit No. 1 Surry Power Station - Life Extension Evaluation of the Reactor Vessel Support 10/10/1986 CE-1653 Review of Structural Adequacy of the Reactor Vessel Support Sliding Foot Assemblies, SPS Units 1 & 2 05/27/2003 N/A Lubrite 2002 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 EPRI TR 3002011710 Irradiation Damage of the Concrete Biological Shield-Basis for Evaluation of the Concrete Biological Shield Wall for Aging Management May 2018 EPRI TR 3002013084 Structural Tools - Long Term Operations:
Subsequent License Renewal Aging Effects for Structures and Structural Components (Excerpts)
December 2018 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