ML20034F330

Regulatory Audit Report Regarding License Amendment Request for Small Break Loss of Coolant Accident Analysis Methodology

ML20034F330
Person / Time
Site:	Surry, North Anna
Issue date:	02/13/2020
From:	Geoffrey Miller Licensing Processes Branch
To:	Stoddard D Dominion
Miller G
References
EPID L-2018-LLA-0195, EPID L-2018-LLA-0215
Download: ML20034F330 (7)

Text

February 13, 2020 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 - REGULATORY AUDIT REPORT REGARDING LICENSE AMENDMENT REQUEST FOR SMALL BREAK LOSS OF COOLANT ACCIDENT ANALYSIS METHODOLOGY (EPID 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.

On December 10, 2019 (ADAMS Accession No. ML19338C690), the U.S. Nuclear Regulatory Commission (NRC) staff issued an audit plan that conveyed intent to conduct a regulatory audit to support its review of the subject license amendment. On January 22-24, 2019, the U.S.

Nuclear Regulatory Commission (NRC) staff conducted the audit at Dominions Innsbrook facility.

The purpose of the audit was to gain understanding, to verify information, and to identify information that will require docketing to support the proposed licensing action. Based on the audit, the NRC staff intends to modify its draft Request for Additional Information (RAI) that were issued to Dominion on November 7, 2019 (ADAMS Accession No. ML19317F104), and issue them formally. The enclosure to this letter provides a report of the NRC staffs audit.

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 Report cc: Listserv

REGULATORY AUDIT REPORT DOMINION ENERGY VIRGINIA (DOMINION)

NORTH ANNA POWER STATION SURRY POWER STAION LICENSE AMENDMENT REQUEST SMALL BREAK LOCA METHODOLOGY DOCKET NOS. 50-338, 50-339, 50-280, AND 50-281

1.0 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 evaluation model for analyzing hypothetical small break loss-of-coolant accidents. By letter dated July 9, 2019, Dominion provided a response to an U.S. Nuclear Regulatory Commission (NRC) staffs request for additional information (RAI). Upon reviewing the supplement, the NRC staff identified that further information was needed to complete the review. A draft RAI was issued to Dominion on November 7, 2019 (ADAMS Accession No. ML19317F104). The draft RAI questions were also used as audit questions during the visit.

On December 10, 2019 (ADAMS Accession No. ML19338C690), the NRC staff issued an audit plan that conveyed intent to conduct a regulatory audit to support its review of the subject license amendment. On January 22-24, 2019, the NRC staff conducted the audit at Dominions Innsbrook facility.

The purpose of the audit was to gain understanding, to verify information, and to identify information that will require docketing to support the proposed licensing action. Based on the audit, the NRC staff intends to modify its draft RAIs that were issued to Dominion on November 7, 2019 (ADAMS Accession No. ML19317F104), and issue them formally. The enclosure to this letter provides a report of the NRC staffs audit.

The NRC staff conducted the regulatory audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Regulatory Audits (ADAMS Accession No. ML082900195).

Enclosure

2.0 SCOPE AND PURPOSE The audit was held on January 22-24, 2020. The purpose of the audit was to help the NRC staff better understand the documentation and analysis results through interaction with the licensees technical experts and to help focus the staffs RAIs on those questions where docketed information is needed to complete the review.

3.0 AUDIT TEAM The following NRC staff members participated in the audit:

Ed Miller - Project Manager Benjamin Parks - Technical Reviewer John Lehning - Technical Reviewer Kevin Heller - Technical Reviewer The following NRC staff members provided support as reviewers for a coincident amendment request from Dominion to implement WCAP-16996-P-A, Realistic LOCA Evaluation Methodology Applied to the Full Spectrum of Break Sizes (FULL SPECTRUM LOCA Methodology), (ADAMS Accession No. ML17277A131).

Fred Forsaty - Technical Reviewer Terrence Brimfield - Technical Reviewer 4.0 AUDIT REPORT The purpose of this regulatory audit was to enhance the staffs technical understanding of the LAR, interact with the licensee technical staff supporting the LAR, and identify what information would need to be docketed to support completion of the review. The audit focus areas were to better understand the licensees proposed methodology and intended application of the analysis.

Table 1 identifies audit participants.

By the conclusion of the audit, the NRC staff indicated that it appeared that there was sufficient understanding of the informational needs associated with RAIs 2 S1, 7 S1, 8 S1, 11 S1, and 16 S1 to anticipate responses that would support completion of the LAR review. The NRC staff identified that NRC staff information needs were better understood for RAIs 12.A S1, 12.B S1, and RAI 18 S1, but that the amount of information needed to complete the review was dependent on whether restrictions on the usage of the methodology would be proposed by the licensee (e.g., types of cladding to which the methodology would be applicable). Finally, it was noted that RAI 6 S1 would need to be modified to fully express the NRC staff information needs regarding both identification of the limiting break size and treatment of peak cladding temperature resultant from delays in tripping of the reactor coolant pumps during such an event.

5.0 DOCUMENTS REVIEWED The following documents were reviewed during the audit:

32-9270402-000 Surry Fuel Vendor-Independent SBLOCA Analysis 32-9244006-002 North Anna Fuel Independent Phase 3 SBLOCA Transient Analysis

32-9251976-001 Justification and Validation of AREVA Fuel Vendor-Independent SBLOCA Analysis 51-9248321-000 Comparison of Zircaloy-4 and Standard/Optimized ZIRLO cladding material properties and fuel rod behavior during SBLOCA ETE-NAF-2017-0136 Evaluation of Fuel Products with Zirconium-Based Alloy Cladding for AREVA Fuel Vendor Independent SBLOCA Analysis ETE-NAF-2019-0036 Verification of Accuracy for Response to NRC Request for Additional Information on North Anna and Surry Fuel-Vendor Independent Small Break Loss of Coolant License Amendment Requests FS1-0043333-R3 SBLOCA Fuel-vendor Independent - RAIs for North Anna and Surry ETE-NAF-2020-0003 Verification of Accuracy for Response to NRC Supplemental Request DRAFT for Additional Information (RAI-S1) on North Anna and Surry Fuel-Vendor Independent Small Break Loss of Coolant License Amendment Requests In addition, the NRC staff was provided with preliminary assimilation of the Framatome document ETE-NAF-2020-0003 into responses to the NRC staff audit questions.

6.0 CONCLUSION

The purpose of the audit was to gain understanding, to verify information, and to identify information that will require docketing to support the proposed licensing action. As a result of the audit, the NRC staff identified that it would revise RAI 6 S1 and issue the draft RAIs formally to Dominion.

Date: February 13, 2020

Table 1 NRC Audit - Attendees January 22-24, 2019 Attendee Name Affiliation Ed Miller NRC-NRR Benjamin Parks NRC-NRR John Lehning NRC-NRR Kevin Heller NRC-NRR Terrance Brimfield NRC-NRR Fred Forsaty NRC-NRR Scott Luchau Dominion Dan Smith Dominion Thu Ho Dominion Nadine Shane Dominion Brian Mount Dominion John Harrell Dominion Lisa Gerkin Framatome Thomas Gardner Framatome Nathan Hottle Framatome Mireille Cortes Framatome

ML20034F330 *Via E-mail OFFICE NRR/DORL/LSPB/PM NRR/DORL/LPL2-1/LA NRR/DSS/SFNB/BC NAME GEMiller KGoldstein RLukes DATE 02/10/2020 02/10/2020 02/10/2020 OFFICE NRR/DORL/LPL2-1/BC NAME MMarkley DATE 02/13/2020