ML21084A182

Subsequent License Renewal Application Response to NRC Requests for Confirmation of Information for the Safety Review - Set 1

ML21084A182
Person / Time
Site:	North Anna
Issue date:	03/24/2021
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
21-073
Download: ML21084A182 (12)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 24, 2021 10 CFR 50 10 CFR 51 10 CFR 54 United States Nuclear Regulatory Commission Serial No.: 21-073 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 {NAPS) UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION (SLRA)

RESPONSE TO NRC REQUESTS FOR CONFIRMATION OF INFORMATION FOR THE SAFETY REVIEW - SET 1

References:

1. Letter from Virginia Electric and Power Company to the US Nuclear Regulatory Commission dated August 24, 2020 (Serial No.20-115), "Virginia Electric and Power Company, North Anna Power Station Units 1 and 2, Application for Subsequent Renewed Operating Licenses," [Agencywide Documents Access and Management System (ADAMS) Accession No. ML20246G697]

2. Email from Lois M. James of the US Nuclear Regulatory Commission to Daniel G. Stoddard of Virginia Electric and Power Company dated March 8, 2021, "FINAL Request for Confirmation of Information (RCI) Set 1 - North Anna SLRA Safety Review," [ADAMS Package Accession No. ML21067A500]

In Reference 1, Virginia Electric and Power Company (Dominion Energy Virginia) submitted the subsequent license renewal application (SLRA) for NAPS Units 1 and 2.

In Reference 2, the NRC provided requests for confirmation of information (RC ls) the staff will likely use in the Safety Evaluation Report for the NAPS SLRA, but which has not been previously docketed. The NRC RCls and Dominion Energy Virginia's confirmation of each RCI are provided in the enclosure.

Serial No.: 21-073 Docket Nos.: 50-338/339 Response to NRC RCls Set 1 - NAPS SLRA Safety Review Page 2 of 6 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.

Acknowledged before me this :1.'t t'h day of March , 2021.

My Commission Expires: J;2./3f 1 I

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CRAIG D SLY Notary Public Commitments made in this letter: None Commonwealth of Virginia Reg. # 7518653 ,iJ.

My Commission Expires December 31, 2o:.!.

Enclosure:

Response to NRC Requests for Confirmation of Information Set 1 - NAPS SLRA Safety Review

Serial No.: 21-073 Docket Nos.: 50-338/339 Response to NRG RCls Set 1 - NAPS SLRA Safety Review Page 3 of 6 cc:

U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Ms. Lois James 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. 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. Vaughn Thomas NRG 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 NRG Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 NRG Senior Resident Inspector North Anna Power Station

Serial No.: 21-073 Docket Nos.: 50-338/339 Response to NRC RCls Set 1 - NAPS SLRA Safety Review Page 4 of 6 Mr. Marcus Harris Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Boulevard Glen Allen, Virginia 23060 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, 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 Mr. James Golden, Regional Director Virginia Department of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060

Serial No.: 21-073 Docket Nos.: 50-338/339 Response to NRC RCls Set 1 - NAPS SLRA Safety Review Page 5 of 6 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. Ryan Brown, Executive Director Director's Office Virginia Department of Wildlife Resources 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 Langan, 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 380 Fenwick Road Building 98 Ft. Monroe, VA 23651 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

Serial No.: 21-073 Docket Nos.: 50-338/339 Response to NRG RCls Set 1 - NAPS SLRA Safety Review Page 6 of 6 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 1070 University Blvd Portsmouth, VA 23703

Serial No.: 21-073 Docket Nos.: 50-338/339 Enclosure RESPONSE TO NRC REQUESTS FOR CONFIRMATION OF INFORMATION SET 1 - NAPS SLRA SAFETY REVIEW Virginia Electric and Power Company (Dominion Energy Virginia)

North Anna Power Station Units 1 and 2

Serial No.: 21-073 Docket Nos.: 50-338/339 Enclosure - Page 2 of 6 Response to NRC Requests for Confirmation of Information Set 1 NAPS SLRA Safety Review North Anna Power Station, Units 1 and 2 Subsequent License Renewal Application By letter dated August 24, 2020, (Agencywide Documents Access and Management System Accession No. ML20246G703), Dominion Energy submitted an application for subsequent license renewal of Renewed Facility Operating License Nos. NPF-4 and NPF-7 for the North Anna Power Station, Unit Nos. 1 and 2 (North Anna) to the U.S.

Nuclear Regulatory Commission (NRC) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and part 54 of title 10 of the Code of Federal Regulations, "Requirements for renewal of operating licenses for nuclear power plants."

The NRC is in the process of reviewing the application. Based on their review, the NRC staff identified requests for confirmation of information (RCls) which will likely be used in the Safety Evaluation Report (SER) for the NAPS SLRA, but which have not been previously docketed. To the best of the staff's knowledge, this information is not on the docket or accessible in the public domain. Any information used to reach a conclusion in the SER must be included on the docket by the applicant.

Clarification calls were held between the NRC staff and Dominion Energy Virginia on February 24 and 25, 2021 and some of the RCls were modified as a result of those calls.

Therefore, in an email dated March 8, 2021, the NRC staff transmitted nine final RCls.

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

RCI No. B2.1.27-A:

Based on the review of procedure 0-EPM-2303-01, "Inspection of Service Water Cathodic Protection System," Revision 15, the staff noted that the acceptance range for instant-off potentials includes an upper bound of-1,200 mV.

During its audit, the staff reviewed the previous revision of procedure 0-EPM 2303 01 (i.e., Revision 14) and noted the acceptance range for instant-off potentials included an upper bound of -1, 500 m V. Confirm that Revision 15 of procedure 0 EPM 2303 01 includes a limiting critical potential of -1,200 m V.

Dominion Response:

This information has been confirmed to be correct as stated.

Serial No.: 21-073 Docket Nos.: 50-338/339 Enclosure - Page 3 of 6 RCI No. B2.1.27-B:

Based on the review of NAS 74, "Yard Water and Fire Protectipn Systems for North Anna Power Station," Revision 4, the staff noted that buried fire protection piping is cast iron with a cement mortar lining and bituminous coating.

Confirm that in scope buried gray cast iron piping is specified to be externally coated with a bituminous coating.

Dominion Response:

This information has been confirmed to be correct as stated.

RCI No. B2.1.27-C:

Based on the review of Design Change No.04-018, "Underground Fire Protection Piping Replacement/ North Anna, Units 1&2, "dated May 18, 2006, the staff noted that buried ductile iron fire protection lines are coated with an asphaltic exterior coating.

Confirm that in scope buried ductile iron piping is specified to be externally coated with an asphaltic coating.

Dominion Response:

This information has been confirmed to be correct as stated.

RCI No. B2.1.27-D:

Based on the review of 11715-FV-46A-8, "Underground Fuel Oil Storage Tanks I EG TK 2A & 28," Revision 8, the staff noted buried fuel oil storage tanks are externally coated with a minimum of 16 mils of Koppers Bitumastic 300-M or equal.

Confirm that in scope buried steel tanks exposed to soil are specified to be externally coated with "Koppers Bitumastic 300-M or equal."

Dominion Response:

This information has been confirmed to be correct as stated.

RCI No. B2.1.27-E:

As amended by letter dated February 4, 2021, Enhancement No. 3 for the Buried and Underground Piping and Tanks program states the following:

The following buried piping materials will be replaced before the last five years of the inspection period prior to entering the subsequent period of extended operation.

(Added - Supplement 1): (a) the buried copper piping between the fire protection jockey pump and the hydropneumatic tank will be replaced with carbon steel; and (b)

Serial No.: 21-073 Docket Nos.: 50-338/339 Enclosure - Page 4 of 6 the buried carbon steel fill line piping for the security diesel fuel oil tank will be replaced with corrosion resistant material that does not require inspection (e.g., titanium alloy, super austenitic, or nickel alloy materials).

Confirm the following: (1) that the piping referenced in parl (a) is the only in-scope (within scope of subsequent licensing renewal) buried copper alloy piping; and (2) that the piping referenced in parl (b) is the only in scope (within scope of subsequent licensing renewal) buried steel piping in the security system.

Dominion Response:

This information has been confirmed to be correct as stated.

RCI No. 82.1.34-A:

Based on the audit review of ER-NA-INS-1047, Revision 10, "Monitoring of Structures Norlh Anna Power Station," the staff verified that the component referenced as "valve body" in SLRA Table 3.5.2-15, "Structures and Components Supporls - Flood Protection Dike - Aging Management Evaluation," is included in the inspection of component reference as "steel culvert" in Attachment 6 of ER-NA-INS-104, "List of Earlhen Structures."

Attachment 6 of ER-NA-INS-104 states that the "steel culvert" associated with the flood wall west of Turbine Building is inspected in accordance with Procedure 1-PT-

9. 3. Procedure 1-PT-9.3 indicates that exposed porlions of the drainpipe and valves associated with the flood wall are inspected.

Confirm that the component referenced as "valve body" in SLRA Table 3.5.2-15, "Structures and Component Supporls - Flood Protection Dike - Aging Management Evaluation," is included in the inspection of the component referenced as "steel culverl" in Attachment 6 of ER-NA-INS-104, "List of Earlhen Structures."

Dominion Response:

This information has been confirmed to be correct as stated.

RCI No. TLAA 4.7.4-A:

Based on the audit review of Calculation 11715-NMB-282-FC, Revision 0, Addendum 008, "Thermal Stress Analysis of Fuel Pool Liner- Fuel Pool Liner Fatigue Evaluation for 80 Years Plant Life, NAPS Units 1 & 2" and supporling referenced Calculation CE-1272, Revision 0, "Analysis of Surry Fuel Pool Liner at 212 Degrees Fahrenheit," the staff noted that Dominion calculated the limiting cumulative damage (or cumulative usage factor) due to fatigue effects of thermal cyclic loadings for the controlling component (i.e., plate- stiffener weld) of the SFP liner from the three design conditions described in the SLRA to be 0.75. This is less than the acceptance criterion of 1.0.

Serial No.: 21-073 Docket Nos.: 50-338/339 Enclosure - Page 5 of 6 Confirm that the limiting cumulative damage (or cumulative usage factor) due to fatigue effects of thermal cyclic loadings calculated for the controlling component (i.e.,

plate-stiffener weld) of the SFP liner from the three design conditions described in SLRA Section 4. 7.4 to be 0. 75.

Dominion Response:

This information has been confirmed to be correct as stated.

RCI No. 3.5.2.2.2.6-A:

Based on the audit review of ETE-SLR-2020-2204, "Assessment of Radiation Effects on Reactor Vessel Supports for NAPS Units 1 & 2," Revision 0, the staff noted that the observed difference in critical stress values for Cases 2 and 4 in ETE-SLR-2020-2204 are small and that Case 2 bounds Case 3, and that Case 4 was analyzed as a quality check for the effect of higher levels of irradiation (reflected by the 62.9 ski yield stress) on the values of critical stress and that Cases 3 and 4 need not be included in SLRA Section 3.5.2.2.2.6.

a. Confirm that observed difference in critical stress values for Cases 2 and 4 in ETE-SLR-2020-2204 are small

b. Confirm that Case 2 bounds Case 3

c. Confirm that Case 4 was analyzed as a quality check for the effect of higher levels of irradiation (reflected by the 62.9 ksi yield stress) on the values of critical stress.

d. Confirm that Cases 3 and 4 need not be included in SLRA Section 3.5.2.2.2.6.

Dominion Response:

a. This information has been confirmed to be correct as stated.

b. This information has been confirmed to be correct as stated.

c. Dominion confirms that Case 4 was an extra check for the effect of higher levels of irradiation (reflected by the 62.9 ksi yield stress) on the values of stress.

d. This information has been confirmed to be correct as stated.

RCI No. 3.5.2.2.2.6-B:

Based on the audit review of ETE-SLR-2020-2204, "Assessment of Radiation Effects on Reactor Vessel Supports for NAPS Units 1 & 2," Revision 0, the staff noted that the inner surface flaw analyzed in Table 1 is for a flaw that that has a depth of 114T; and stresses in Figures 1 through 4 of ETE-SLR-2020-2204 was back calculated from the applied stress intensity factor (K) set equal to Kie and that the critical stress in Table 1 of SLRA Section 3.5.2.2.2.6 came from these plots.

Serial No.: 21-073 Docket Nos.: 50-338/339 Enclosure - Page 6 of 6

a. Confirm that the inner sutiace flaw analyzed in Table 1 is for a flaw that that has a depth of 114T

b. Confirm stresses in Figures 1 through 4 of ETE-SLR-2020-2204 was back calculated from the applied stress intensity factor (K) set equal to KIC

c. Confirm that the critical stress in Table 1 of SLRA Section 3.5.2.2.2.6 came from these plots.

Dominion Response:

a. This information has been confirmed to be correct as stated.

b. Dominion confirms that the stresses in Figures 1 through 4 of ETE-SLR-2020-2204 were back calculated. Specifically, equations were used to solve for Sm with Kie equal to 33.2 ksh/in. Figures 1 through 4 of ETE-SLR-2020-2204 were generated using a best fit second order polynomial expression to illustrate the relationship of Sm and Kie.

c. This information has been confirmed to be correct as stated, with the clarification that the critical stress values in Table 1 of SLRA Section 3.5.2.2.2.6 were back calculated as described in the Dominion Response to RCI 3.5.2.2.2.6-B, Item b, above.