ML19267A042

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Subsequent License Renewal Application Response to NRC Requests for Confirmation of Information Set 2
ML19267A042
Person / Time
Site: Surry  
Issue date: 09/16/2019
From: Mark D. Sartain
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
19-367
Download: ML19267A042 (14)
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 16, 2019 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION Serial No.:

NRA/DEA:

Docket Nos.:

10 CFR 50 10CFR51 10 CFR 54 License Nos.:

19-367 R1 50-280 50-281 DPR-32 DPR-37 RESPONSE TO NRC REQUESTS FOR CONFIRMATION OF INFORMATION SET 2

References:

1. Letter from Virginia Electric and Power Company to the US Nuclear Regulatory Commission dated October 15, 2018 (Serial No.18-340), "Virginia Electric and Power Company, Surry Power Station Units 1 and 2, Application for Subsequent Renewed Operating Licenses," [Agencywide Documents Access and Management System (ADAMS) Accession No. ML18291A842]
2. Email from Emmanuel Sayoc of the US Nuclear Regulatory Commission to Daniel G. Stoddard of Virginia Electric and Power Company dated August 20, 2019, "Requests for Confirmation of Information for the Safety Review of the Surry Power Station, Units 1 and 2 Subsequent License Renewal Application (L-2018-RNW-0023/000951) - (Attachment 4D)"

In Reference 1, Virginia Electric and Power Company (Dominion Energy Virginia) submitted the Subsequent License Renewal Application (SLRA) for Surry Power Station (SPS) Units 1 and 2. In Reference 2, the NRC provided requests for confirmation of information (RCls) the staff will likely use in the conclusions documented in their Safety Evaluation Report (SER) for the SLRA, but which has not been previously docketed.

Dominion Energy Virginia's response to each RCI is provided in Enclosure 1 and the SLRA mark-ups are provided in Enclosure 2.

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Serial No.19-367 Docket Nos. 50-280/281 SLRA - Response to NRC RCls - Set 2 Page 2 of 6 If you have any questions or require additional information, please contact Mr. Paul Aitken at (804) 273-2818.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Commitments made in this letter: None

Enclosures:

1. Response to Requests for Confirmation of Information - Set 2 - Regarding SPS SLRA
2. SLRA Mark-ups - Set 2 RCls COMMONWEAL TH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering and Fleet Support of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this ICa +" day of Sefrl'~, 2019.

My Commission Expires: A~:f'A.+ ~ \\, 'Z,..c, Z 3, GARY DON MILLER Notary Public Commonwealth of Virginia Reg. # 7629412 My Commission Expires August 31, 2~

cc:

(w/o Enclosures except*)

Serial No.19-367 Docket Nos. 50-280/281 SLRA - Response to NRC RCls - Set 2 Page 3 of 6 U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE.

Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station Mr. Billy Rogers*

NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Tam Tran*

NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Ms. Angela Wu*

NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Vaughn Thomas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 04 F-12 11555 Rockville Pike Rockville, Maryland 20852-2738

Mr. G. Edward Miller NRC Senior Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 State Health Commissioner Virginia Department of Health James Madison Building - th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. David K. Paylor, Director Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Melanie D. Davenport, Director Water Permitting Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Bettina Rayfield, Manager Office of Environmental Impact Review Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. Michael Dowd, Director Air Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. Justin Williams, Director Division of Land Protection and Revitalization Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Serial No.19-367 Docket Nos. 50-280/281 SLRA - Response to NRC RCls - Set 2 Page 4 of 6

Serial No.19-367 Docket Nos. 50-280/281 SLRA - Response to NRC RCls - Set 2 Mr. James Golden, Regional Director Virginia Department of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060 Mr. Craig R. Nicol, Regional Director Virginia Department of Environmental Quality Tidewater Regional Office 5636 Southern Blvd Virginia Beach, VA 23462 Ms. Jewel Bronaugh, Commissioner Virginia Department of Agriculture & Consumer Services 102 Governor Street Richmond, Virginia 23219 Mr. Jason Bulluck, Director Virginia Department of Conservation & Recreation Virginia Natural Heritage Program 600 East Main Street, 24th Floor Richmond, VA 23219 Mr. Robert W. Duncan, Director Virginia Department of Game and Inland Fisheries P.O. Box 90778 Henrico, VA 23228 Mr. Allen Knapp, Director Virginia Department of Health Office of Environmental Health Services 109 Governor St, 5th Floor Richmond, VA 23129 Ms. Julie Lagan, Director Virginia Department of Historic Resources State Historic Preservation Office 2801 Kensington Ave Richmond, VA 23221 Mr. Steven G. Bowman, Commissioner Virginia Marine Resources Commission 2600 Washington Ave Newport News, VA 23607 Page 5 of 6

Serial No.19-367 Docket Nos. 50-280/281 SLRA - Response to NRC RCls - Set 2 Dr. Mary Fabrizio, Professor Virginia Institute of Marine Science School of Marine Science 7509 Roper Rd, Nunnally Hall 135 Gloucester Point, VA 23062 Ms. Angel Deem, Director Virginia Department of Transportation Environmental Division 1401 East Broad St Richmond, VA 23219 Mr. Stephen Moret, President Virginia Economic Development Partnership 901 East Byrd St Richmond, VA 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Public Utility Regulation 1300 East Main St, 4th Fl, Tyler Bldg Richmond, VA 23219 Mr. Jeff Caldwell, Director Virginia Department of Emergency Management 10501 Trade Rd Richmond, VA 23236 Mr. Bruce Sterling, Chief Regional Coordinator Virginia Department of Emergency Management 7511 Burbage Drive Suffolk, VA 23435 Mr. Jonathan Lynn, Administrator Surry County 45 School Street Surry, VA 23883 Page 6 of 6 Serial No.: 19-367 Docket Nos.: 50-280/281 RESPONSE TO NRC REQUESTS FOR CONFIRMATION OF INFORMATION SET 2 REGARDING SPS SLRA Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2

Serial No.: 19-367 Docket Nos.: 50-280/281 Page 1 of 3 Response to NRC Requests for Confirmation of Information Set 2 Subsequent License Renewal Application Surry Power Station Units 1 and 2 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 an application for the subsequent license renewal of Renewed Facility Operating License Nos. DPR-32 and DPR-37 for Surry Power Station (SPS) Units 1 and 2, respectively.

Between February 4 and April 25, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff conducted audits of Dominion records to confirm information submitted in the SPS Subsequent License Renewal Application (SLRA). During the audits, the staff reviewed several documents that contain information that will likely be used in conclusions documented in the Safety Evaluation Report (SER), but which has not been previously submitted to the NRC on the docket.

Any information used to reach a conclusion in the SER must be included on the docket by the applicant.

Therefore, in an email dated August 20, 2019, the NRC staff transmitted two requests for confirmation of information (RCls) gathered during the audits noted above.

The NRC RCls and Dominion Energy Virginia's confirmation of each RCI are provided below.

REQUESTS FOR CONFIRMATION OF INFORMATION (RCls)

RCI No. 1:

1. SLRA Table 3.2.1, item 3.2.1-028; Table 3.3.1, items 3.3.1-043 and 3.3.1-044; and Table 3.4.1, item 3.4.1-023, state that there are no in-scope stainless steel piping or piping components; or steel with stainless steel cladding or stainless steel heat exchanger components exposed to closed-cycle cooling water greater than 60°C (greater than 140°F) in the engineered safety features systems, auxiliary systems, and steam and power conversion systems, respectively.

UFSAR Table 9.4-1, "Component Cooling Water Design Data," states that the component cooling water pumps have a design temperature of 180°F and the heat exchangers, surge tanks, and chemical addition tanks have a design temperature of 150°F.

UFSAR Table 9.4-1 states that the maximum operating temperature for the component cooling water heat exchangers is 119. 7°F.

However, it is not clear to the staff that all in-scope stainless steel piping and piping components and steel with stainless steel cladding or stainless steel heat exchanger components exposed to closed-cycle l

Serial No.: 19-367 Docket Nos.: 50-280/281 Page 2 of 3 cooling water are exposed to temperatures less than 140°F because UFSAR Section 9. 4. 1. 1 states that, "[t]he component cooling water system is designed to reduce the temperature of the reactor coolant to 140°F based on a river water temperature of 100°F." While the UFSAR does not conflict with these AMR items, it could be possible that there are in-scope stainless steel or steel with stainless steel cladding components exposed to temperatures greater than 140°F.

Confirm that there are no in-scope stainless steel piping or piping components or steel with stainless steel cladding or stainless steel heat exchanger components exposed to closed-cycle cooling water greater than 140°F or system conditions greater than 140°F while being exposed to closed-cycle cooling water in the engineered safety features systems, auxiliary systems, and steam and power conversion systems.

Dominion Response:

During operation of the alternate AC diesel generator engine, portions of the alternate AC diesel generator jacket water cooling subsystem are exposed to closed-cycle cooling water >60°C (>140°F). The cooling subsystem contains stainless steel restricting orifices which, therefore, are exposed to closed-cycle cooling water >60°C

(>140°F). As a result, the Closed Treated Water Systems (B2.1.12) program will manage the aging effect of cracking for the stainless steel restricting orifices.

There are no other stainless steel piping or piping components, steel with stainless steel cladding or stainless steel heat exchanger components exposed to closed-cycle cooling water >60°C (>140°F) that are subject to aging management review in the engineered safety features systems, auxiliary systems, and steam and power conversion systems.

SLRA Changes SLRA Tables 3.3.1 and 3.3.2-37 and Section 3.3.2.1.37 are supplemented, as shown in, to reflect aging management of the stainless steel restricting orifices described above.

RCI No. 2:

Serial No.: 19-367 Docket Nos.: 50-280/281 Page 3 of 3 SLRA Table 3.2.1, item 3.2.1-029 states that there are no in-scope steel piping or piping components exposed to closed-cycle cooling water in the engineered safety features systems.

UFSAR Section 9.4.2 states, "[cjarbon steel pipe is used throughout the system." While the UFSAR does not conflict with item 3.2.1-029, it could be possible that there are in-scope steel piping or piping components exposed to closed-cycle cooling water in the engineered safety features systems.

Confirm that there are no in-scope steel piping or piping components exposed to closed-cycle cooling water in the engineered safety features systems.

Dominion Response:

This information has been confirmed to be correct as stated.

SLRA MARK-UPS SET 2 RCls Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2 Serial No.: 19-367 Docket Nos.: 50-280/28 1

Set 2 RCls 3.3.2.1.37 Materials Alternate AC Surry Power Station, Units 1 and 2 Application for Subsequent License Renewal Aging Management Review The materials of construction for the alternate ac system component types are:

  • Elastomer
  • Glass
  • Stainless steel
  • Steel
  • Steel with internal coating Environment The alternate ac system component types are exposed to the following environments:
  • Air - dry
  • Air - indoor uncontrolled
  • Air - outdoor
  • Closed-cycle cooling water
  • Closed-cycle cooling water >60°C (>140°F)
  • Condensation
  • Diesel exhaust
  • Fuel oil
  • Lubricating oil Page3-251 Page 1 of 3

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report Item Component Number 3.3.1-040 Stainless steel piping, piping components exposed to raw water 3.3.1-042 Copper alloy, titanium, stainless steel heat exchanger tubes exposed to raw water, raw water (potable), treated water 3.3.1-043 Stainless steel piping, piping components exposed to closed-cycle cooling water

>60°C (>140°F) 3.3.1-044 Stainless steel; steel with stainless steel cladding heat exchanger components exposed to closed-cycle cooling water >60°C

(>140°F)

Surry Power Station, Units 1 and 2 Application for Subsequent License Renewal Aging Aging Management EffectlMechanism Program Loss of material due AMP XI.M20, Open-Cycle to pitting, crevice Cooling Water System corrosion, MIC; flow blockage due to fouling Cracking due to sec AMP XI. M20, Open-Cycle (titanium only),

Cooling Water System, or reduction of heat AMP XI.M38, Inspection of transfer due to fouling Internal Surfaces in Miscellaneous Piping and Ducting Components Cracking due to sec AMP XI.M21A, Closed Treated Water Systems Cracking due to sec AMP XI.M21A, Closed Treated Water Systems Page 3-293 Further Evaluation Recommended No No No No Discussion Consistent with NUREG-2191 with exceptions.

Exceptions apply to the NUREG-2191 recommendations for Open-Cycle Cooling Water System (B2.1.11) progra m implementation. Flow blockage is not an applicable aging effect requiring management for nonsafety-related components that do not support a function of delivering downstream flow, or for strainer elements that are monitored for clogging.

Consistent with NUREG-2191 with exceptions. Cracking (titanium only) and reduction of heat transfer of copper alloy or titanium heat exchanger tubes exposed to raw water is managed by the Open-Cycle Cooling Water System (B2.1.11) program. Cracking of titanium components other than heat exchanger tubes exposed to treated water is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.25) program. Exceptions apply to the NUREG-2191 recommendations for Open-Cycle Cooling Water System (B2.1.11) program implementation.

~le! a13131ieaele. SPS Ras Re iR sea13e slaiRless sleel 13i13iR§, 13i13iR§ eeffl13eReRls e1113esea le slesea sysle seeliR§,,..,aleF "eQ 0 G E"14Q°F) iR !Re,o,1c111ilial)' Sysleffls.

TRe assesialea ~JURf;G 2191 agiR§ ileffls aFe Rel 1c1sea.

CQn§i§t!;ln! with N\\,!RE~-21~1 wi!h !;lX!;;!;lQtiQn§.

EXC!iRlion§ aQRlll to the NUR!;G-2191 recomm!;lnQ;,i\\iQn§ fQr CIQ§!iQ Tr!;l;,i!ed W;,i\\!;lr S)ls\\em§ (B2.1.12) QrQgrgm imRl!iment;,iliQD Not applicable. SPS has no in-scope stainless steel or steel with stainless steel cladding heat exchanger components exposed to closed-cycle cooling water

>60°C (>1 40°F) in the Auxiliary Systems. The associated NU REG-2191 aging items are not used.

Page 2 of 3 Set 2 RC ls

Table 3.3.2-37 Auxiliary Systems - Alternate AC - Aging Management Evaluation Component Intended Material Type Function(s)

Heater housing PB Steel uacket water)

Heater housing PB Steel (lubricating oil)

Lubricator body PB Copper alloy

(>15% Zn)

Motor casing (air PB Gray cast start motor) iron Orifice PB;RF Stainless steel Surry Power Station, Units 1 and 2 Application for Subsequent License Renewal Environment (E) Air - indoor uncontrolled (I) Closed-cycle cooling water (E) Air - indoor uncontrolled (I) Lubricating oil (I) Air - dry (E) Air - indoor uncontrolled (I) Air - dry (E) Air - indoor uncontrolled (E) Air - indoor uncontrolled (I) Closed-cycle cooling water (ll (;;loseQ-!2LQI~

QQOling wat~r

>(IQ°C (> 14Q°F)

Aging Effect Requiring Aging Management Programs Management Loss of material External Surfaces Monitoring of Mechanical Components (B2.1.23)

Loss of material Closed Treated Water Systems (82.1.12)

Loss of material External Surfaces Monitoring of Mechanical Components (B2.1.23)

Loss of material Lubricating Oil Analysis (B2.1.26)

One-lime Inspection (82.1.20)

Loss of material Compressed Air Monitoring (B2.1.14)

None None Loss of material Compressed Air Monitoring (82.1.14)

Loss of material External Surfaces Monitoring of Mechanical Components (B2.1.23)

Cracking External Surfaces Monitoring of Mechanical Components (82.1.23)

Loss of material External Surfaces Monitoring of Mechanical Components (B2.1.23)

Loss of material Closed Treated Water Systems (B2.1.12)

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(;;IQ§eg Tr~2!~d W2ter Sts!em§ (B2.1.12l Page 3-535 NUREG-2191 Table 1 Notes Item Item VII.I.A-77 3.3.1-078 A

VII.C2.AP-189 3.3.1-046 B

VII.I.A-77 3.3.1-078 A

V JJ.H2.AP-131 3.3.1-098 A

VII.H2.AP-131 3.3.1-098 A

V JJ.D.A-764 3.3.1-235 A

VI J.J.AP-1 44 3.3.1-114 A

VII.D.A-764 3.3.1-235 A

Vll.1.A-77 3.3.1-078 A

VI I.H2.AP-209b 3.3.1-004 A

VII. H2.AP-221 b 3.3.1-006 A

VII.C2.A-52 3.3.1-049 B

VIJ.(;;2AP-1 !;!(2 ll1-Q4~

.6.

Set 2 RCls Page 3 of 3

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