ML20246G697

Application for Subsequent Renewed Operating Licenses

ML20246G697
Person / Time
Site:	North Anna
Issue date:	08/24/2020
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20246G703	List: ML20246G697 ML20246G698 ML20246G700 ML20246G701 ML20246G706 ML20246G707 ML20246G709
References
20-115
Download: ML20246G697 (16)

Text

PROPRIETARY INFORMATION -WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 10 CFR 50 10 CFR 51 August24,2020 10 CFR 54 United States Nuclear Regulatory Commission Serial No.: 20-115 Attention: Document Control Desk NRA/DEA: RO Washington, D.C. 20555-0001 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 APPLICATION FOR SUBSEQUENT RENEWED OPERATING LICENSES Pursuant to 10 CFR Parts 50, 51, and 54, Virginia Electric and Power Company (Dominion Virginia Power or Dominion) is submitting this Application for Subsequent Renewed Operating Licenses for North Anna Power Station (NAPS) Units 1 and 2. The existing Renewed Facility Operating Licenses, Nos. NPF-4 and NPF-7 for NAPS Units 1 and 2, respectively, currently expire as follows:

• At midnight on April 1, 2038 for Unit 1

• At midnight on August 21, 2040 for Unit 2 Virginia Electric and Power Company seeks to extend the respective operating terms by 20 years beyond the current renewed license expiration dates.

The enclosed Subsequent License Renewal Application (SLRA) contains the information required by 10 CFR Parts 54 and 51 and meets the submittal timeliness requirements of 10 CFR 54.17(c) and 10 CFR 2.109(b).

As required by 10 CFR 54.21(b), current licensing basis changes which have a material effect on the content of this application will be submitted at least annually while the application is under NRG review and at least three months prior to the scheduled completion of the NRG review.

Appendix A, Table A4.0-1, of the enclosed NAPS SLRA provides a list of commitments made in this application. This list will be updated as required throughout the SLRA review process.

ifhe Application for Subsequent Renewed Operating Licenses for NAPS Units 1 and 2 consists of the following five

Enclosures:

Enclosure 1: North Anna Power Station Subsequent License Renewal Application Enclosure Summary Enclosure 2: Application for Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 A /) 3 5 AJR~ contains information that is being withheld from public disclosure under 10 CFR 2.390.

Upon separation from Enclosure 5, this letter is decontrolled.

Serial No.: 20-115 Docket Nos.: 50-338/339 SLRA Submittal Page 2 of 8 Enclosure 3: North Anna Power Station Subsequent License Renewal Application (CD-ROM titled, "NAPS_SLRA")

Enclosure 4: Non-proprietary Reference Documents and a Redacted Version of a Proprietary Reference Document (Public Version)

Enclosure 5: 10 CFR 2.390 Withheld Proprietary Document The NAPS SLRA (Enclosure 3), which includes the Environmental Report, is being submitted on CD-ROM. The CD-ROM labeled, "NAPS_SLRA," contains the following two files (file size specified in parenthesis):

001 NAPS_SLRA_(Public).pdf (9,099,909 bytes) 002 NAPS_Environmental_Report_(Public).pdf (35,809,495 bytes)

Since Enclosure 5 contains proprietary information, it is supported by an affidavit signed by the owner of the information (Enclosure 2). The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b )(4) of 10 CFR 2.390.

Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in .accordance with 10 CFR 2.390. A redacted, non-proprietary version is provided in Enclosure 4 as noted above.

During a telecom on June 2, 2020, the NRC informed Dominion of the delay in the

, issuance of a forthcoming Interim Staff Guidance . (ISG) document related to aging management review and inspection requirements of Reactor Vessel Internals for the subsequent license renewal period. The NRC staff also communicated to Dominion that the technical basis for the ISG, using updated industry guidance documents during the presentation by industry members of the Nuclear Energy Institute at public meetings conducted on February 20, 2020 and April 7, 2020 [Agencywide Document Access and Management System (ADAMS) Accession Nos. ML20036E364 and ML20098D185, respectively], was found to be acceptable by the NRC staff. Based on the discussion, the NRC informed Dominion that a detailed "Gap Analysis" was not required to be incorporated into Appendix C of the SLRA, but necessary supporting information should be made available for NRC review during the Safety review phase. At the end of the telecom, Dominion affirmed that following issuance of the ISG, a separate review would be performed to ensure the various elements of the ISG were evaluated. If information presented in the NAPS SLRA required a change, then a supplement would be provided later, at a mutually agreed upon date.

Serial No.: 20-115 Docket Nos.: 50-338/339 SLRA Submittal Page 3 of 8 If there are any questions regarding this submittal or if additional information is needed, please contact Mr. Paul Aitken at (804) 273-2818.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support COMMONWEALTH 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.

i----------Aeknowledged-before-mathis-d.!:I +k day~o~f~A'----'-"L\~jt'Y"'"":S""t:.___'--',2=-:0=--=2:.: .0.:_._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

My Commission Expires: 12 j31 \ zo Commitments made in this letter:

The Licensee Commitments identified in Table A4.0-1 of Appendix A, UFSAR Supplement, are proposed to support approval of the subsequent renewed operating licenses and may change during the NRC review period.

Serial No.: 20-115 Docket Nos.: 50-338/339 SLRA Submittal Page 4 of 8

Enclosures:

- North Anna Power Station Subsequent License Renewal Application Enclosure Summary - Application for Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 Attachment 1 - CAW-20-4998, Affidavit for WCAP-11163-P, Revision 2 - North Anna Power Station Subsequent License Renewal Application (CD-ROM titled: "NAPS_SLRA") - Non-proprietary Reference Documents and a Redacted Version of a Proprietary Reference Document (Public Version)

Attachment 1 - PWROG-18005-NP, Revision 2 Attachment 2-WCAP -18353-NP, Revision 0 Attachment 3-WCAP -18364-NP, Revision 1 Attachment 4-WCAP-11164-NP, Revision 2 (Redacted version of WCAP-11163-P) - 10 CFR 2.390 Withheld Proprietary Document Attachment 1 - WCAP-11163-P, Revision 2

Serial No.: 20-115 Docket Nos.: 50-338/339 SLRA Submittal Page 5 of 8 cc: (Enclosure 3 CD-ROM copy only)

U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 NRG Senior Resident Inspector North Anna Power Station Mr. David Drucker NRG Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike

--~

Rockv1ff~lVTarylancr20852;;;2'138*--------

Mr. Tam Tran NRG Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. G. Edward Miller NRG Senior Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop O-9E3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Marcus Harris Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Boulevard Glen Allen, Virginia 23060

Serial No.: 20-115 Docket Nos.: 50-338/339 SLRA Submittal Page 6 of 8 State Health Commissioner Virginia Department of Health James Madison Building - 7th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. David K. Paylor, Director Virginia Department of Environmental Quality P.O. Box 1105 Richmond, Virginia 23218 Ms. Melanie D. Davenport, Director Water Permitting Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, Virginia 23218 Ms. Bettina Rayfield, Manager Office of Environmental Impact Review Virginia Department of Environmental Quality P.O. Box 1105 Richmond, Virginia 23218 Mr. Michael Dowd, Director Air Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, Virginia 23218 Mr. Justin Williams, Director Division of Land Protection and Revitalization Virginia Department of Environmental Quality P.O. Box 1105 Richmond, Virginia 23218 Mr. James Golden, Regional Director Virginia Department of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, Virginia 23060

Serial No.: 20-115 Docket Nos.: 50-338/339 SLRA Submittal Page 7 of 8 Mr. Craig R. Nicol, Regional Director Virginia Department of Environmental Quality Tidewater Regional Office 5636 Southern Boulevard Virginia Beach, Virginia 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, Virginia 23219 1~--------1Mr_RoberLW~D~unca11,~D~i~re~c~to=r~----------------------~

Virginia Department of Wildlife Resources P.O. Box 90778 Henrico, Virginia 23228 Mr. Allen Knapp, Director Virginia Department of Health Office of Environmental Health Services 109 Governor Street, 5th Floor Richmond, Virginia 23129 Ms. Julie Lagan, Director Virginia Department of Historic Resources State Historic Preservation Office 2801 Kensington Avenue Richmond, Virginia 23221 Mr. Steven G. Bowman, Commissioner Virginia Marine Resources Commission 2600 Washington Avenue Newport News, Virginia 23607

Serial No.: 20-115 Docket Nos.: 50-338/339 SLRA Submittal Page 8 of 8 Dr. Mary Fabrizio, Professor Virginia Institute of Marine Science School of Marine Science 7509 Roper Road, Nunnally Hall 135 Gloucester Point, Virginia 23062 Ms. Angel Deem, Director Virginia Department of Transportation Environmental Division 1401 East Broad Street Richmond, Virginia 23219 Mr. Stephen Moret, President Virginia Economic Development Partnership 901 East Byrd Street Richmond, Virginia 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Public Utility Regulation 1300 East Main Street, 4th Floor, Tyler Building Richmond, Virginia 23219 Mr. Jeff Caldwell, Director Virginia Department of Emergency Management 10501 Trade Road Richmond, Virginia 23236 Mr. Bruce Sterling, Chief Regional Coordinator Virginia Department of Emergency Management 1070 University Boulevard Portsmouth, Virginia 23703

Serial No.: 20-115 Docket Nos.: 50-338/339 Enclosure 1 NORTH ANNA POWER STATION SUBSEQUENT LICENSE RENEWAL APPLICATION ENCLOSURE

SUMMARY

Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

Serial No.: 20-115 Docket Nos.: 50-338/339 Enclosure 1 Page 2 of 2 ENCLOSURE

SUMMARY

Enclosure 1 - North Anna Power Station Subsequent License Renewal Application Enclosure Summary Enclosure 2 - Application for Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390

Attachment:

CAW-20-4998 - Westinghouse Affidavit for WCAP-11163-P, Revision 2, "Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for North Anna Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 Years) Leak-Before- Break Evaluation," January 2020 (Proprietary)

• Enclosure 3 - North Anna Power Station Subsequent License Renewal Application (CD-ROM titled: "NAPS_SLRA")

Enclosure 4 - Non-proprietary Reference Documents and a Redacted Version of a Proprietary Referenc_e_Document-(P1;1blic-Versioff) 1 - - - - - ~ ~ _Attachment

_-~ 1: PWROG-18005-NP, Revision 2, "Determination of Unirradiated RTNOT and Upper-Shelf Energy Values of the North Anna Units 1 and 2 Reactor Vessel Materials," September 2019 Attachment 2: WCAP-18353-NP, Revision 0, "Reactor Internals Fluence Evaluation for a Westinghouse 3-Loop Plant with Two Units -

Subsequent License Renewal," October 2018 Attachment 3: WCAP-18364-NP, Revision 1, "North Anna Units 1 and 2 Time-Limited Aging Analysis on Reactor Vessel Integrity for Subsequent License Renewal (SLR)," March 2020 Attachment 4: WCAP-11164-NP, Revision 2, "Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for North Anna Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 Years) Leak-Before- Break Evaluation," January 2020 (Redacted version of WCAP-11163-P)

Enclosure 5 - 10 CFR 2.390 Withheld Proprietary Document

Attachment:

WCAP-11163-P, Revision 2, Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for North Anna Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 Years) Leak-Before- Break Evaluation," January 2020

Serial No.: 20-115 Docket Nos.: 50-338/339 Enclosure 2 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390 Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

Serial No.: 20-115 Docket Nos.: 50-338/339 Enclosure 2 Attachment CAW-20-4998 WESTINGHOUSE AFFIDAVIT FORWCAP-11163-P. REVISION 2 Virginia Electric and Power Company

{Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

Westinghouse Non-Proprietary Class 3 CA W-20-4998 Page I of3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER:

(1) I, Camille T. Zozula, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of WCAP-11163-P, Revision 2 be withheld from public disclosure under IO CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or finam.:ial infurmalion.

(4) Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii) Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluati0n justifications and licensing defense services for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

Westinghouse Non-Proprietary Class 3 CA W-20-4998 Page 2 of3 AFFIDAVIT (5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process ( or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage ( e.g., by optimization or improved mark.dability ).

(c) Its use by a competitor would reduce his expenditure ofresources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These

Westinghouse Non-Proprietary Class 3 CA W-20-4998 Page3 of3 AFFIDAVIT lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (t) of this Affidavit.

l declare that the avennents of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: l1 ,jCLVJ wW I I i

1 l.

i

l.Jti!ity Cu~tomer_ Instru_cti~ns Include the following informationJn the TRANSMITTAL LETTER to NRC. This is_ not part ... - of the affidavit.

Enclosed is:

(I) CA W-20-4998 (2) WCAP-11163-P, Revision 2, "Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for North Anna Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 Years) Leak-Before-Break Evaluation," January 2020 (Proprietary).

(3) WCAP-11164-NP, Revision 2, "Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for North Anna Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 Years) Leak-Before-Break Evaluation," January 2020 (Non-Proprietary).

The enclosure contains information proprietary to Westinghouse Electric Company LLC

("Westinghouse"), it is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the considerations listed in paragraph (b )(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CA W-20-4998 and should be addressed to Camille T. Zozula, Manager, Infrastructure & Facilities Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Suite 165, Cranberry Township, Pennsylvania 16066.