ML21312A001

Comments on North Anna Draft SER

ML21312A001
Person / Time
Site:	North Anna
Issue date:	11/04/2021
From:	Aitken P Dominion Energy Co, Virginia Power (Virginia Electric & Power Co)
To:	Lois James NRC/NRR/DNRL/NLRP
James L, NRR/DNRL/NLRP, 301-415-3306
Shared Package
ML21312A000	List: ML21312A001 ML21312A003 ML21312A007 ML21312A008 ML21312A011
References
EPID L-2020-SLR-0000
Download: ML21312A001 (3)

Text

From: paul.aitken@dominionenergy.com To: James, Lois Cc: Gibson, Lauren; Caldwell, Bob; Keith.J.Miller@dominionenergy.com; craig.h.heah@dominionenergy.com

Subject:

[External_Sender] North Anna Draft SER Comments Date: Thursday, November 04, 2021 11:39:46 AM Attachments: image001.png RE NAPS SLR SER Appendix A for Dominion review.msg Attachment 2 - NAPS Draft SER Table A.1-1 Markup.pdf Attachment 3 - NAPS Draft SER Section 3 Comments.pdf

Lois, Thank you for providing the draft SER and meeting your milestone to support the ACRS meeting on 12/15. The SLR team has reviewed it and compiled recommended revisions to draft SER Table A.1-1 and SER Section 3 based on NRC/Dominion Energy correspondence during the application review process.

By way of background, you previously provided a copy of the initial draft SER Table A.1-1, which documents the Dominion Energy SLR commitments, for review and comment. As you recall, I had the SLR team review the table and provide comments - Attachment 1 is the 9/21 email that provided our comments in tracked change format, as well as a clean copy of Table A.1-1.

SER Table A.1-1 Revisions During our review SER Table A.1-1 is very important, since it will be incorporated into the UFSAR, and provides all the SLR commitments that Dominion will be responsible for closing. We have reviewed the revised Table A.1-1 provided in the draft SER against the comments we previously provided and have created a new markup. Our recommended revisions for SER Table A.1-1 are shown in redline/strikeout format in Attachment 2. There were several general themes of comments identified for SER Table A.1 they are provided as follows with examples:

1. Several commitments that had edits recommended by Dominion are still shown in strikethrough, instead of the change being fully implemented. For example, commitment #5 for the Buried Pipe program still contains strikethrough text that should be removed entirely.

2. Completed commitments need to be deleted in their entirety from the table and remaining commitments renumbered accordingly. For example, commitments #1 & 4 for Fuel Oil Chemistry have been deleted and the existing commitments #2 an #3 should be re-numbered to be #1 and #2.

3. Some completed commitments were still shown in strikethrough. For example, the lined-through commitment #5 in Fire Water. Like 1a, the strikethrough text needs to be deleted completely.

4. Any references to Dominion correspondence in parenthesis should be deleted, e.g., (Added -

Supplement 4), (Updated - RAI Set 2), etc. An example is shown for the Flow Accelerated Corrosion program. The final SER with these changes would be consistent with the Surry SER.

SER Section 3 Revisions Additionally, the SLR team noted some revisions needed in SER Section 3 for the Staff evaluations of the Aging Management Programs. These comments also followed some general themes, which are provided as follows with examples:

5. The counts of exceptions and enhancements discussed in section 3 are not always consistent with the commitments in Table A.1-1. Generally, this appears to be a result of not subtracting the completed commitments. An example is Fuel Oil Chemistry, section 3.0.3.2.11, page 3-66. The discussion documents five exceptions and enhancements.

However, there is now only one exception and two enhancements.

6. The enhancements that have been completed are not always documented as such in the SER discussions. As an example, enhancements 1 & 4 of Fuel Oil Chemistry are completed, but are not reflected as such in section 3.0.3.2.11. Another example is enhancement 8 of Fire Water in Section 3.0.3.2.9.

7. The time period for implementation of the aging management programs is not always consistent with the time periods for implementation denoted in Table A.1-1. For example, Fuel Oil Chemistry (section 3.0.3.2.11, page 3-68 quotes ongoing implementation of the existing Fuel Oil Chemistry Program. Table A.1-1 reflects program will be implemented and inspections begin 10 years before).

The comments on SER Section 3 are provided in Attachment 3 with a cross-reference to the generic comment number from above that applies to it.

Thanks for your consideration - after youve had a chance to review, perhaps we can have a call to discuss any questions.

Regards, Paul Aitken Engineering Manager Subsequent License Renewal Dominion Energy Services, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 (804) 273-2818 (Office)

(804) 356-9590 (Cell)*

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