ML19338C690

Audit Plan License Amendment Request for Small Break Loss of Coolant Accident Methodology (Epids L-2018-LLA-0195 and L-2018-LLA-0215)

ML19338C690
Person / Time
Site:	Surry, North Anna
Issue date:	12/10/2019
From:	Geoffrey Miller Plant Licensing Branch II
To:	Stoddard D Southern Nuclear Operating Co
Miller G, 415-2481
References
EPID L -2018-LLA-0195, EPID L-2018-LLA-021
Download: ML19338C690 (6)

Text

December 10, 2019 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNITS 1 AND 2 AND SURRY POWER STATION, UNITS 1 AND 2 - AUDIT PLAN RE: LICENSE AMENDMENT REQUEST FOR SMALL BREAK LOSS OF COOLANT ACCIDENT METHODOLOGY (EPIDS L-2018-LLA-0195 AND L-2018-LLA-0215)

Dear Mr. Stoddard:

By letter dated July 12 and July 31, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML18198A118 and ML18218A170, respectively), Dominion Energy Virginia (Dominion), submitted license amendment requests regarding the North Anna Power Station (North Anna), Units 1 and 2 and Surry Power Station (Surry), Units 1 and 2. The proposed amendments would enable each station to implement a fuel vendor-independent evaluation model for analyzing hypothetical small break loss-of-coolant accidents.

The U.S. Nuclear Regulatory Commission (NRC) staff will conduct a regulatory audit to support its review of the proposed license amendments. The audit is planned to be conducted on-site at North Anna to facilitate access to the licensees computer models, documentation, and technical experts. The NRC staff intends to start the audit on January 22, 2020. A detailed audit plan is enclosed. The logistics and scope of the audit will be coordinated with your staff sufficiently in advance of the start date to allow for your preparation.

D. Stoddard If you have any questions, please contact me by telephone at (301) 415-2481 or by e-mail at ed.miller@nrc.gov.

Sincerely,

/RA/

G. Edward Miller, Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338, 50-339, 50-280, and 50-281

Enclosure:

Audit Plan cc: Listserv

AUDIT PLAN SMALL BREAK LOSS-OF-COOLANT ACCIDENT METHODOLOGY DOMINION ENERGY VIRGINIA NORTH ANNA POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-389 SURRY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-280 AND 50-281 I. BACKGROUND By letter dated July 12 and July 31, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML18198A118 and ML18218A170, respectively), Dominion Energy Virginia (Dominion), submitted license amendment requests regarding the North Anna Power Station (North Anna), Units 1 and 2, and Surry Power Station (Surry), Units 1 and 2. The proposed amendments would enable each station to implement a fuel vendor-independent (FVI) evaluation model (EM) for analyzing hypothetical small break loss-of-coolant accidents (LOCAs).

The U.S. Nuclear Regulatory Commission (NRC) staff is performing a detailed review of the proposed license amendment request (LAR). Due to the complexity of the proposed amendment, the NRC staff has determined that an audit can resolve complex technical issues more quickly than several rounds of requests for additional information (RAI). Face-to-face interactions will also allow the staff to review and assess physical aspects of the LAR at the site through field walkdowns.

The NRC staff has scheduled a regulatory audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Regulatory Audits, for the NRC staff to gain a better understanding of the licensee's calculations and other aspects supporting the LAR.

II. REGULATORY AUDIT BASES A regulatory audit is conducted with the intent to gain understanding, to verify information and/or to identify information that will require docketing to support the basis for the proposed licensing or regulatory decision.

NRC Regulatory Requirements The licensee proposes to implement an FVI version of the EM described in Licensing Topical Report (LTR) EMF-2328(P)(A), PWR Small Break LOCA Evaluation Model S-RELAP5 Based, as supplemented by, plant-specific analysis reports. This EM is based on the required and acceptable features of Emergency Core Cooling System (ECCS) EMs contained in Appendix K to 10 CFR 50; therefore, 10 CFR 50, Appendix K serves as a regulatory basis for this audit.

Enclosure

III. REGULATORY AUDIT SCOPE AND METHODOLOGY The audit will cover the following documents and topics:

• ANP-3467P, Revision 0, North Anna Fuel-Vendor Independent Small Break LOCA Analysis Licensing Report

• ANP-3676P, Surry Fuel-Vendor Independent Small Break LOCA Analysis

• Calculation notes and related documentation supporting the above licensing reports

• Division of responsibility among licensee, fuel vendor, and EM furnisher, concerning the use of the proposed EM

• Adequacy of steady-state and transient fuel thermal-mechanical modeling

• Criteria and methods for re-executing the SB LOCA analyses

• Applicability of methods to new fuel designs and criteria to establish functional similarity to prior fuel designs

• Sensitivity studies, if any have been done, concerning differences in thermal-hydraulic design and fuel behavior over the expected range of fuel designs

• Reactor Coolant Pump (RCP) trip timing sensitivity studies described in ANP-3467P and ANP-3676P The audit will be performed consistent with NRCs Office of Nuclear Reactor Regulation (NRR)

Office Instruction LIC-111, Regulatory Audits, dated December 29, 2008 (ADAMS Accession No. ML082900195).

IV. INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT By e-mail dated November 7, 2019 (ADAMS Accession No. ML19317F104), the NRC staff transmitted draft RAIs to your staff. Please provide access to information and references that will assist in refining and responding to the referenced NRC staff informational needs.

Additional information needs, identified during the audit, will be communicated to the designated point of contact.

The audit team will not remove non-docketed information from the audit site.

V. AUDIT TEAM ASSIGNMENTS The NRC/NRR audit team onsite will consist of:

Ed Miller, Audit Team Lead, Project Manager, Division of Operating Reactor Licensing (DORL)/Plant Licensing Branch 2-1 (LPL2-1)

Benjamin Parks, Technical Reviewer, Division Safety Systems (DSS)/ Nuclear Methods and Fuel Analysis Branch (SNPB)

John Lehning, Technical Reviewer, Technical Reviewer, DSS/SNPB Kevin Heller, Technical Reviewer, DSS/SNPB VI. LOGISTICS The NRC staff will conduct the audit on January 22, 2020, on a mutually agreeable schedule and agenda. The NRC Project Manager will coordinate any changes to the audit schedule and location with the licensee.

VII. SPECIAL REQUESTS The NRC staff requests access to the following equipment and services:

Escorted or unescorted access to germane locations within the protected area of the plant as appropriate; Enclosed conference room (or comparable space) with a table, chairs, and white board sufficient to accommodate NRC participants and supporting licensee staff; and Computer access to any onsite electronic portal applicable for this audit.

VIII. DELIVERABLES At the conclusion of the audit, the NRC staff will conduct an exit briefing and provide a summary of audit results in each subject area defined in the audit scope, as well as discuss the projects next steps. Once the NRC audit team leaves the site, only new, post-site audit documents added to the electronic portal will continue to be reviewed and audited.

The NRC staff plans to prepare a regulatory audit summary within 60 days of the completion of the audit followed by a formal release of any RAIs at that time.

ML19338C690 *Via E-mail OFFICE NRR/DORL/LSPB/PM NRR/DORL/LPL2-1/LA NRR/DSS/SNPB/BC NAME GEMiller KGoldstein RLukes DATE 12/09/19 12/04/19 12/09/19 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/LSPB/PM NAME MMarkley GEMiller DATE 12/09/19 12/10/19