Text

Enclosure 1 - E-mail - Enclosure B - NAPS SER App a - Dominion Comments 9-21-2021
	ML21312A007
Person / Time
Site:	North Anna
Issue date:	09/21/2021
From:	; Dominion Energy Co, Virginia Power (Virginia Electric & Power Co)
To:	; Office of Nuclear Reactor Regulation
	James L, NRR/DNRL/NLRP, 301-415-3306
Shared Package
ML21312A000	List: ML21312A001; ML21312A003; ML21312A007; ML21312A008; ML21312A011;
References
	EPID L-2020-SLR-0000
	Download: ML21312A007 (76)
	v • d • e

LICENSE RENEWAL COMMITMENTS

A. License Renewal Commitments During the review of the North Anna Power Station, Units 1 and 2 (NAPS) subsequent license renewal application by the staff of the U.S. Nuclear Regulatory Commission (NRC or the staff),

Virginia Electric and Power Company (Dominion Energy or the applicant) made commitments related to the aging management programs (AMPs) used to manage aging effects for structures and components. The following Table lists these commitments along with the implementation schedules and sources for each commitment. The subsequent period of extended operation for NAPS begins on May 25, 2032, for Unit 1 and January 29, 2033, for Unit 2.

A-1

Table A.1-1 NAPS License Renewal Commitments NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments 1 ASME Section XI XI.M1 The ASME Section XI B2.1.1 Program Application, Aug. Review Complete -Added NUREG-2191 Section Inservice Inspection, Inservice Inspection, enhancements for 24, 2020, Subsections IWB, Subsections IWB, IWC, and SLR will be Dom-20-115, IWC, and IWD IWD program is an existing implemented 6 ML20246G703 program condition monitoring program months prior to the that will be enhanced as subsequent period of follows: extended operation.

1. Procedures will be revised to require inspections be performed for the following:

a. Welds associated with sentinel locations assessed under ASME Code,Section XI, Appendix L include the safety injection 6-inch diameter RCS cold leg A-1 nozzles. One safety injection cold leg nozzle is to be inspected once per 10 years for either Unit 1 or Unit 2.

b. The pressurizer spray nozzle stainless steel-to-safe-end weld is to be inspected once per 10 years for each unit.

2. Procedures will be revised to require periodic volumetric inspections of the steam generator feedwater nozzle thermal sleeves.

2 Water Chemistry XI.M2 The Water Chemistry B2.1.2 Ongoing Application, Review Complete -Added NUREG-2191 Section program program is an existing Aug. 24, 2020, preventive program that is Dom-20-115, credited. ML20246G703

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments 3 Reactor Head XI.M3 The Reactor Head Closure B2.1.3 Ongoing Application, Review Complete -Added NUREG-2191 Section Closure Stud Bolting Stud Bolting program is an Aug. 24, 2020, program existing condition monitoring Dom-20-115, program that is credited. ML20246G703 4 Boric Acid Corrosion XI.M10 The Boric Acid Corrosion B2.1.4 Ongoing Application, Review Complete -Added NUREG-2191 Section program program is an existing Aug. 24, 2020, condition monitoring program Dom-20-115, that is credited. ML20246G703 5 Cracking of XI.M11B The Cracking of Nickel-Alloy B2.1.5 Ongoing Application, Review Complete -Added NUREG-2191 Section Nickel-Alloy Components and Loss of Aug. 24, 2020, Components and Material Due to Boric Dom -115, Loss of Material Due Acid -Induced Corrosion in ML20246G703 to Boric Acid-Induced Reactor Coolant Pressure Corrosion in Reactor Boundary Components Coolant Pressure program is an existing Boundary condition monitoring program Components program that is credited.

6 Thermal Aging XI.M12 The Thermal Aging B2.1.6 Ongoing Application, Review Complete -Added NUREG-2191 Section Embrittlement of Cast Embrittlement of Cast Aug. 24, 2020, Austenitic Stainless Austenitic Stainless Steel Dom-20-115, A-2 Steel (CASS) (CASS) program is an ML20246G703 program existing condition monitoring program that is credited.

7 PWR Vessel Internals XI.M16A The PPPWR Vessel Internals B2.1.7 Program, accounting Application,

Review Complete -Added NUREG-2191 program program is an existing for the impacts of a Aug. 24, 2020, Section condition monitoring program gap analysis, will be Dom-20-115,

Removed Enhancement #2 since it had that will be enhanced as implemented 6 ML20246G703 been deleted by Supplement 1.

follows: months prior to the

Renumbered the remaining enhancements Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

subsequent period of Supplement 1, to be #2 and #3, instead of #3 and #4.

1. Procedures will be revised extended operation, Feb. 4, 2021, Aligned at: 0.25" + Indent at: 0.5" to provide guidance for or alternatively, a Dom-20-416, inspections of the following plant-specificplant- ML21035A303 reactor vessel internal specific program may components in accordance be implemented 6 with the referenced report for months prior to the each item: subsequent period of extended operation.

a. Control rod guide tube (CRGT) lower flange weld (MRP-227, Revision 1-A, Materials Reliability Program:

Pressurized Water Reactor

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments Internals Inspection and Evaluation Guidelines)

b. CRGT guide plates (cards) and the lower guide tube continuous Section sheaths and C-tubes (WCAP-17451-P, Revision 2, "Reactor Internals Guide Tube Wear - Westinghouse Domestic Fleet Operational Projections") (Revised -

Supplement 1)

c. Core barrel upper flange weld (UFW) (MRP-227, Revision 1-A)

d. Core barrel lower girth weld (LGW) (MRP-227, A-3 Revision 1-A)

e. Core barrel middle axial weld (MAW) and lower axial weld (LAW) (MRP-227, Revision 1-A)

f. Core barrel upper axial weld (UAW) (MRP-227, Revision 1-A)

g. Core barrel upper girth weld (UGW) (MRP-227, Revision 1-A)

h. Core barrel lower flange weld (LFW) (MRP-227, Revision 1-A)

i. Baffle-edge bolts (MRP-227, Revision 1-A)

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

j. Baffle plates (MRP-227, Revision 1-A)

k. Baffle-former bolts (MRP-227, Revision 1-A)

l. Barrel-former bolts (MRP-227, Revision 1-A)

m. Bottom-mounted instrumentation column bodies (MRP-227, Revision 1-A)

n. Lower support column bodies (MRP-227, Revision 1-A)

o. Lower support column bolts (MRP-227, Revision 1-A)

A-4

p. Clevis insert bolts (MRP 2018-022, Transmittal of MRP-191 Screening, Ranking, and Categorization Results and Interim Guidance in Support of Subsequent License Renewal at U.S.

PWR Plants)

q. Clevis insert dowels (MRP 2018-022)

r. Stellite' wear surface on radial support keys (MRP 2018-022)

s. Stellite' wear surface on clevis inserts (MRP 2018-022)

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

t. Fuel alignment pins for lower core plate (MRP 2018-022)

u. Fuel alignment pins for upper core plate (MRP 2018-022)

2. (Deleted - Supplement 1)

32. Procedures will be revised to provide acceptance criteria for inspection results for the following reactor vessel internal components in accordance with MRP-227, Revision 1-A:

a. Thermal shield flexures A-5 b. Lower support forging

c. Upper core plate

43. Procedures will be revised to provide guidance for one-time inspections of the core barrel MAW and LAW in accordance with MRP 2019-009, Transmittal of NEI 03-08 Good Practice Interim Guidance Regarding MRP-227-A and MRP-227, Revision 1, PWR Core Barrel and Core Support Barrel Inspection Requirements.

8 Flow-AcceleratedFlow XI.M17 The Flow -Accelerated B2.1.8 Program Application,

Review Complete -Added NUREG-2191 Accelerated Corrosion program is an enhancements for Aug, 24Aug, 24, Section Corrosion program existing condition monitoring SLR will be 2020,

The Implementation Schedule was changed program that is credited. implemented 6 Dom-20-115, to On-going since all Enhancements have (Updated - RAl Set 2) months prior to the ML20246G703 been completed during the review subsequent period of

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments extended RAI Set 2

Deleted Dominion letter number from Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

operationOngoing. Response, Commitment text Aligned at: 0.25" + Indent at: 0.5" Apr. 29, 2021, Dom 21-134, ML21119A287 9 Bolting Integrity XI.M18 The Bolting Integrity program B2.1.9 Program Application, Review Complete -Added NUREG-2191 Section program is an existing condition enhancements for Aug. 24, 2020, monitoring program that will SLR will be Dom-20-115, be enhanced as follows: implemented 6 ML20246G703 months prior to the

1. Procedure(s) will be subsequent period of enhanced to: extended operation.

a. Iinclude inspections of pressure-retaining bolting in inaccessible areas when they become accessible by means such as excavation, dewatering, or shielding/barrier removal, and A-6

b. iInclude a requirement during opportunistic maintenance activities to document the condition of bolt heads and threads.

2. Procedure(s) will be developed and/or revised to provide instructions for performing inspections of pressure boundary bolting for plant locations that preclude detection of joint leakage including bolting in submerged environments, bolting for air or gas systems, and bolting for piping systems not normally pressurized as follows:

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

a. Submerged closure bolting is visually inspected for loss of material during maintenance activities. In this case, bolt heads are inspected when made accessible, and bolt threads are inspected when joints are disassembled. In each 10-year period during the subsequent period of extended operation, for each unit, a representative sample of bolt heads and threads is inspected up to a maximum of 19 bolts for each material and environment combination. If opportunistic maintenance activities will not provide access to 20% of the A-7 population (for a material/environment combination) up to a maximum of 19 bolt heads and threads over a 10-year period, then periodic pump vibration measurements are taken and trended.

b. For air or gas systems, inspections are performed consistent with that of submerged closure bolting.

Closure bolting for air or gas systems is visually inspected for loss of material during maintenance activities. In this case, bolt heads are visually inspected when made accessible, and bolt threads are visually inspected when joints are disassembled. In

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments each 10-year period during the subsequent period of extended operation, for each unit, a representative sample of bolt heads and threads is inspected up to a maximum of 19 bolts for each material and environment combination. If opportunistic maintenance activities will not provide access to 20% of the population (for a material/environment combination) up to a maximum of 19 bolt heads and threads over a 10-year period, then soap bubble testing will be performed.

c. For piping systems not A-8 normally pressurized, the torque of the bolting will be checked to the extent that the closure bolting is not loose. In each 10-year period during the subsequent period of extended operation, for each unit, a representative sample of bolt heads and threads is inspected up to a maximum of 19 bolts for each material and environment combination.

3. Procedure(s) will be developed and/or revised to evaluate sampling -based inspections against plant-specific acceptance criteria to confirm that the sampling bases (e.g.,

selection, size, frequency) will maintain the components'

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments intended functions throughout the subsequent period of extended operation based on the projected rate and extent of degradation. If any projected inspection results will not meet acceptance criteria prior to the next scheduled inspection, sampling frequencies will be evaluated and adjusted as determined by the corrective action program. Bolting that is unsuitable for continued use will be replaced. If the cause of the aging effect for each applicable material and environment is not corrected by repair or replacement for all components constructed of A-9 the same material and exposed to the same environment, additional inspections will be conducted if one of the inspections does not meet acceptance criteria.

The number of increased inspections is determined in accordance with the site's corrective action process; however, there are no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20% of each applicable material and environment combination is inspected, whichever is less.

If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis is

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments conducted to determine the further extent of inspections.

Additional samples are inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. The additional inspections include inspections of components with the same material and environment combination for each unit and are completed within the 10-year inspection interval in which the original inspection was conducted.

10 Steam Generators XI.M19 The Steam Generators B2.1.10 Ongoing Application, Review Complete -Added NUREG-2191 Section program program is an existing Aug. 24, 2020, condition monitoring program Dom-20-115, that is credited. ML20246G703 A-10 11 Open-Cycle Cooling XI.M20 The Open -Cycle Cooling B2.1.11 Ongoing Application, Review Complete -Added NUREG-2191 Section Formatted: Underline, Font color: Red Water program Water program is an existing Aug. 24, 2020, condition monitoring program Dom-20-115, that is credited. ML20246G703 12 Closed Treated Water XI.M21A The Closed Treated Water B2.1.12 Program Application, Review Complete -Added NUREG-2191 Section Systems program Systems program is an enhancements for Aug. 24, 2020, existing condition monitoring SLR will be Dom-20-115, program that will be enhanced implemented 6 ML20246G703 as follows: months prior to the subsequent period of

1. A new procedure will be extended operation.

developed to specify that in each 10-year period during the subsequent period of extended operation, the minimum number of inspections is completed for the various sample populations (each material, water treatment program, and aging effect combination). If opportunistic inspections will

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments not fulfill the minimum number of inspections by the end of each 10-year period, the program owner will initiate work orders as necessary to request additional inspections. A representative sample of 20% of the population (defined as components having the same material, water treatment program, and aging effect combination) or a maximum of nineteen components per population at each unit will be inspected. The new procedure will specify that the inspections focus on the bounding or lead components most susceptible to aging due A-11 to time in service, and severity of operating conditions.

2. A new procedure will be developed to specify that, where practical, the rate of any degradation is evaluated and projected until the end of the subsequent period of extended operation or the next scheduled inspection, whichever is shorter. The sampling bases (e.g.,

selection, size, frequency) will be adjusted as necessary based on the projection.

3. A new procedure will be developed to specify that additional inspections will be performed if any inspections

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments do not meet the acceptance criteria, unless the cause of the aging effect for each applicable material and environment is corrected by repair or replacement. There will be no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20% of each applicable material, environment, and aging effect combination inspected, whichever is less.

If any subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis will be conducted to determine the further extent of A-12 inspections required.

Additional samples will be inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. The additional inspections will include inspections of components with the same material, environment, and aging effect combination at both Unit 1 and Unit 2. The additional inspections will be completed within the interval (e.g., refueling outage interval, 10-year inspection interval) in which the original inspection was conducted.

13 Inspection of XI.M23 The Inspection of Overhead B2.1.13 Ongoing Application, Review Complete -Added NUREG-2191 Section Formatted: Underline, Font color: Red Overhead Heavy Heavy Load and Light Load Aug. 24, 2020, Load and Light Load (Related to Refueling)

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments (Related to Refueling) Handling Systems program is Dom- 20-115, Handling Systems an existing condition ML20246G703 program monitoring program that is credited.

14 Compressed Air XI.M24 The Compressed Air B2.1.13 Ongoing Application, Review Complete -Added NUREG-2191 Section Monitoring program Monitoring program is an Aug. 24, 2020, existing condition monitoring Dom-20-115, program that is credited. ML20246G703 15 Fire Protection XI.M26 The Fire Protection program B2.1.15 Program Application, Review Complete -Added NUREG-2191 Section program is an existing condition enhancements for Aug. 24, 2020, monitoring program that will SLR will be Dom-20-115, be enhanced as follows: implemented 6 ML20246G703 months prior to the

1. Procedures for fire barrier subsequent period of penetration seals, fire extended operation.

barriers, fire damper assemblies, and fire doors will be revised to require, where practical, identified degradation to be projected A-13 until the next scheduled inspection. For sampling-based inspections, results are evaluated against acceptance criteria to confirm that the sampling bases (e.g.,

selection, size, frequency) will maintain the components' intended functions throughout the subsequent period of extended operation based on the projected rate and extent of degradation.

2. Procedures will be revised to require that if degradation is detected within the inspection sample of penetration seals, the scope of the inspection is expanded to include additional seals in accordance with the

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments Corrective Action Program.

Additional inspections would be 20% of each applicable inspection sample; however, additional inspections would not exceed five. If any projected inspection results will not meet acceptance criteria prior to the next scheduled inspection, inspection frequencies are adjusted as determined by the Corrective Action Program.

16 Fire Water System XI.M27 The Fire Water System B2.1.16 Program will be Application,

Review Complete -Added NUREG-2191 Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

program program is an existing implemented and Aug. 24, 2020, Section Aligned at: 0.25" + Indent at: 0.5" condition monitoring and inspections or tests Dom-20-115,

Deleted Enhancement 5 IAW Supplement 3 performance monitoring begin 5 years before ML20246G703

Deleted references to Dominion letters in program that will be enhanced the subsequent Commitment text Formatted: Font color: Red as follows: period of extended Supplement 1,

Re-numbered commitments operation. Feb. 4, 2021, Formatted: Font color: Red A-14 1. Procedures will be Inspections or tests Dom-20-416, developed or revised to that are to be ML21035A303 Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

specify: completed prior to the Aligned at: 0.25" + Indent at: 0.5" subsequent period of Supplement 1,

a. Standpipe and system flow extended operation Dom-21-075 tests for hose stations at the are completed 6 Mar. 17, 2021, hydraulically most limiting months prior to the ML21076B025 locations for each zone of the subsequent period of system on a five-year interval extended operation RAI Set 4 to demonstrate the capability or no later than the Response and to provide the design last refueling outage Supplement 3, pressure at required flow prior to the Dom-21-213, subsequent period of Jul. 29, 2021,

b. Wet pipe main drain testing extended operation. ML21210A396 will be performed on 20% of the standpipes and risers every 18 months on a refueling cycle basis.

Acceptance criteria will be based upon monitoring flowing pressures from test to test to determine if there is a

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments 10% reduction in full flow pressure when compared to previously performed tests.

The Corrective Action Program will determine the cause and necessary corrective action.

c. If a flow test or a main drain test does not meet acceptance criteria due to current or projected degradation additional tests are conducted. The number of increased tests is determined in accordance with the corrective action process; however, there are no fewer than two additional tests for each test that did not meet A-15 acceptance criteria. The additional inspections are completed within the interval in which the original test was conducted. If subsequent tests do not meet acceptance criteria, an extent of condition and extent of cause analysis is conducted to determine the further extent of tests. The additional tests include at least one test at the other unit with the same material, environment, and aging effect combination.

d. Main drains for the standpipes associated with hose stations within the scope of subsequent license renewal will also be added to

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments main drain testing procedures.

2. Procedures will be revised to perform internal visual inspections of sprinkler and deluge system piping to identify internal corrosion, foreign material, and obstructions to flow.

FollowupFollow-up volumetric examinations will be performed if internal visual inspections detect an unexpected level of degradation due to corrosion product deposition. If organic or foreign material, or internal flow blockage that could result in failure of system function is A-16 identified, then an obstruction investigation will be performed within the Corrective Action Program that includes removal of the material, an extent of condition determination, review for increased inspections, extent of followupfollow-up examinations, and a flush in accordance with NFPA 25, 2011 Edition, Annex D.5, Flushing Procedures. The internal visual inspections will consist of the following:

a. Wet pipe sprinkler systems - 50% of the wet pipe sprinkler systems in scope for subsequent license renewal will have visual internal

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments inspections of piping by removing a hydraulically remote sprinkler, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2. During the next five-year inspection period, the alternate systems previously not inspected shall be inspected.

b. Pre-action sprinkler systems - pre-action sprinkler systems in scope for subsequent license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent A-17 with NFPA 25, 2011 Edition, Section 14.2.

c. Deluge systems - deluge systems in scope for subsequent license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

3. Procedures will be revised to perform system flow testing at five-year intervals with flows representative of those expected during a fire. A flow resistance factor (C-factor) will be calculated to compare and trend the friction loss

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments characteristics to the results from previous flow tests.

4. Procedures will be revised to address recurring internal corrosion with the use of Low Frequency Electromagnetic Technique (LFET) or a similar technique on 100 feet of piping during each refueling cycle to detect changes in the pipe wall thickness. The procedure will specify thinned areas found during the LFET screening be followed up with pipe wall thickness examinations to ensure aging effects are managed and wall thickness is within acceptable limits. In addition to the pipe A-18 wall thickness examination, the performance of opportunistic visual inspections of the fire protection system will be required whenever the fire water system is opened for maintenance. The piping age, time in service, and susceptibility to corrosion should be considered in determining sample location priorities.

5. The activity of the jockey pump (i .e., an increase in the number of pump starts or run time of the pump) will be monitored consistent with the "detection of aging effects" program element of NUREG-2191,Section XI.M41 .

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments (Relocated from original Commitment 6 - Supplement

2) (Deleted - Supplement 3) Formatted: Strikethrough 6.5. The Unit 2 lube oil Formatted: Strikethrough purification piping will have the piping pitch adjusted to improve drainage. A drain valve will be installed on the Unit 2 hydrogen seal oil fire protection piping to drain the line after system testing or initiation. As part of the drainage reconfiguration, visual inspections and wall thickness measurements will be performed to identify unexpected degradation.

Piping with unexpected degradation will be replaced.

A-19 (Revised - Supplement 1) Formatted: Strikethrough (Renumbered - Supplement 2)

7. (Relocated to new Formatted: Strikethrough Commitment 5 - Supplement 2}

8 6. Procedures will be Formatted: Strikethrough revised for wet pipe sprinkler systems, a one-time test of sprinklers that have been exposed to water including the sample size, sample selection criteria, and minimum time in service of tested sprinklers will be performed. At each unit, a sample of 3% or a maximum of ten sprinklers with no more than four sprinklers per structure shall be tested.

Testing is based on a

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments minimum time in service of fifty years and severity of operating conditions for each population.

(Revised - Supplement 1) Formatted: Strikethrough (Completed - Supplement 2) 9 7. Procedures will be Formatted: Strikethrough revised to perform a visual inspection of the fire protection pump suction strainers for loss of material on a 12-year frequency.

(Added - Supplement 3) Formatted: Strikethrough 17 Outdoor and Large XI.M29 The Outdoor and Large B2.1.17 Program will be Application,

Review Complete -Added NUREG-2191 Atmospheric Metallic Atmospheric Metallic Storage implemented and Aug. 24, 2020, Section Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

Storage Tanks Tanks program is an existing inspections or tests Dom-20-115,

Deleted reference to Dominion letter number Aligned at: 0.25" + Indent at: 0.5" program condition monitoring program begin 10 years before ML20246G703 in Commitment text that will be enhanced as the subsequent follows: period of extended Supplement 1, A-20 operation. Feb. 4, 2021,

1. Procedures will be revised Inspections or tests Dom-20-416, to require periodic visual that are to be ML21035A303 inspections of the RWSTs completed prior to the and CCTs be performed at subsequent period of Supplement 4, each refueling outage to extended operation Dom-21-280, confirm that the mastic are completed 6 Aug. 26, 2021, sealant at the RWSTs and months prior to the ML21238A297 CCTs insulation and concrete subsequent period of foundation interface is intact. extended operation The visual inspections of the or no later than the sealant will be supplemented last refueling outage with physical manipulation to prior to the detect any degradation. If subsequent period of there are any identified flaws, extended operation.

the mastic sealant will be repaired or replaced, and follow-up examination of the tank's surfaces will be conducted if deemed appropriate. An inspection of the caulk at the tank and

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments concrete foundation interface will be included in the sample when the RWSTs and CCTs external insulation is removed and the caulk will be sampled for external surface visual examinations ten years before the subsequent period of extended operation. Results will be forwarded to Engineering for evaluation and the need for additional inspections will be determined based on projected corrosion rates.

2. Procedures will be revised to require the caulking at the ECST vent and vacuum breaker penetration-concrete A-21 missile barrier interface be inspected on a 18-month frequency to confirm that the caulking is intact. The visual inspections will be supplemented with physical manipulation to detect any degradation. If there are any identified flaws. the caulking will be repaired or replaced.

(Added - Supplement 4}

3. Procedures will be revised to require visual and surface examination of the exterior surfaces of the RWSTs, CATs, and CCTs be performed to identify any loss of material or cracking. A minimum of either 25 one-square foot sections or 20% of the surface area of

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments insulation will be required to be removed to permit inspection of the exterior surface of each tank. The procedure will specify that sample inspection points be distributed in such a way that inspections occur near the bottoms, at points where structural supports, pipe, or instrument nozzles penetrate the insulation, and where water could collect such as on top of stiffening rings. If no unacceptable loss of material or cracking is observed, subsequent external surface examinations of insulated tanks will inspect for indications of damage to the A-22 jacketing, evidence of water intrusion through the insulation, or evidence of damage to the moisture barrier of tightly adhering insulation. (Renumbered -

Supplement 4}

4. Unit 1 ECST: Procedures will be revised to require one-time thickness measurements of a sample of the Unit 1 ECSTs interior wall and tank bottom prior to the subsequent period of extended operation to assess potential degradation due to leakage identified from the missile shield into the pipe penetration area in the Auxiliary Feedwater Pump House. The samples will

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments examine the ECSTs interior vertical steel shell region from the bottom of the tank along the pipe penetration area, extending six feet vertically up from the tank, as this is a region potentially most susceptible to external surface degradation. Tank bottom thickness measurements will also be performed. The inspection results will be projected to the end of the subsequent period of extended operation to confirm the Unit 1 ECSTs intended functions will be maintained throughout the subsequent period of extended operation based on A-23 the projected rate of degradation. Any degradation not meeting acceptance criteria will require periodic 10-year thickness measurements and a sample expansion along the leakage path consistent with the observed degradation.

Unit 2 ECST: The Unit 2 ECST external vertical wall degradation projections to the end of the subsequent period of extended operation that exceed less than 0.1 inch wall thickness will be repaired prior to entering the subsequent period of extended operation. Periodic inspections of a minimum of five locations with the lowest

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments wall thickness readings will be performed on a ten-year inspection frequency.

Inspection results projected to the end of the subsequent period of extended operation that do not meet acceptance criteria will require an extent of condition and extent of cause to determine the further extent of inspection and corrective actions. Tank bottom thickness measurements will also be performed.

(Revised - Supplement 1)

(Renumbered - Supplement 4}

5. Procedures will be revised to require volumetric A-24 examination thickness measurements of the bottom of the RWSTs and CCTs be performed each 10-year period during the subsequent period of extended operation starting ten years before the subsequent period of extended operation. Results will be forwarded to Engineering for evaluation and the need for additional inspections will be determined based on projected corrosion rates. (Renumbered -

Supplement 4)

6. A new procedure will be developed to specify that additional inspections be performed consistent with NUREG-2191. If any

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments inspections do not meet the acceptance criteria, additional inspections are conducted if one of the inspections does not meet acceptance criteria due to current or projected degradation (i.e., trending).

(Renumbered - Supplement 4)

a. For inspections where only one tank of a material, environment, and aging effect was inspected, all tanks in that grouping are inspected.

b. For other sampling based inspections there will be no fewer than five additional inspections for each inspection that did not meet A-25 acceptance criteria, or 20% of each applicable material, environment, and aging effect combination inspected, whichever is less. If any subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis will be conducted to determine the further extent of inspections required.

Additional samples will be inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. The additional inspections will include inspections of components with the same material, environment, and

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments aging effect combination at the other unit. The additional inspections will be completed within the interval (i.e.,

10-year inspection interval) in which the original inspection was conducted or, if identified in the latter half of the current inspection interval, within the first half of the next inspection interval. These additional inspections conducted in the next inspection interval cannot also be credited towards the number of inspections in the latter interval. If any projected inspection results will not meet acceptance criteria prior to the next scheduled A-26 inspection, inspection frequencies are adjusted as determined by the Corrective Action Program. However, for one-time inspections that do not meet acceptance criteria, inspections are subsequently conducted at least at 10-year inspection intervals.

18 Fuel Oil Chemistry XI.M30 The Fuel Oil Chemistry B2.1.18 Program will be Application,

Review Complete -Added NUREG-2191 program program is an existing implemented and Aug. 24, 2020, Section condition monitoring program inspections begin 10 Dom-20-115,

Deleted completed enhancements and Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

that will be enhanced as years before the ML20246G703 notes. Renumbered commitments follows: subsequent period of Aligned at: 0.25" + Indent at: 0.5" extended operation. Supplement 1,

1. The Fuel Oil Chemistry Inspections that are Feb. 4, 2021, program scope will be revised to be completed prior Dom-20-416, to include the security diesel to the subsequent ML21035A303 generator fuel oil day tank. period of extended (Completed - Supplement 1) operation are completed 6 months prior to the

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

12. Procedure(s) will be subsequent period of revised or developed to drain, extended operation clean internally to the extent or no later than the practical, visually inspect last refueling outage internal surfaces (if physically prior to the possible), and perform tank subsequent period of bottom thickness extended operation.

measurements of the following tanks:

(Revised - Supplement 1)

Emergency diesel generator fuel oil day tanks (procedures are currently available to drain and clean on demand)

SBO diesel generator fuel oil day tank (new procedure needed)

Diesel-driven fire pump 2 fuel oil storage tank (new procedure needed)

A-27

Security diesel generator fuel oil day tank (new procedure needed),

Underground fuel oil storage tanks (procedures are currently available).

The procedure(s) will require that if evidence of degradation is observed during visual inspection, or if visual inspection is not possible, volumetric inspections will be performed. The draining, cleaning and inspection of each tank will be performed at least once during the 10-year period prior to the subsequent period of extended operation and at least once every 10 years during the subsequent period of operation.

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments Procedure(s) will be revised or developed as needed to require an Engineering evaluation be performed to evaluate and trend visual and volumetric (if degradation is detected during inspections) tank inspection results.

Unacceptable inspection results will be documented in the Corrective Action Program. Thickness measurements will be evaluated against the design thickness and corrosion allowance. The rate of degradation is evaluated and projected until the end of the subsequent period of extended operation or the A-28 next scheduled inspection, whichever is shorter. The inspection frequency will be adjusted, as necessary, based on the projection.

23. Procedures will be revised or developed to perform a one-time draining, cleaning and internal visual inspection of the security diesel generator fuel oil supply tank between 30 and 40 years of service. Any degradation found during the internal visual inspection will be addressed by the Corrective Action Program. If degradation is observed, volumetric measurements will be performed.

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

4. Procedures will be updated to clarify the need to specifically monitor and trend water and biological activity in addition to particulates.

(Completed - Supplement 1) 19 Reactor Vessel X1.M31 The Reactor Vessel Material B2.1.19 Ongoing Application, Review Complete -Added NUREG-2191 Section Material Surveillance Surveillance program is an Aug. 24, 2020, program existing condition monitoring Dom-20-115, program that is credited. ML20246G703 20 One-Time Inspection XI.M32 The One-Time B2.1.20 Program will be Application,

Review Complete -Added NUREG-2191 Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

program InspectionOne-Time implemented and Aug. 24, 2020, Section Aligned at: 0.25" + Indent at: 0.5" Inspection program is a new inspections begin 10 Dom-20-115,

To be consistent throughout the table, the condition monitoring program years before the ML20246G703 name of the program should be in italics Formatted: Font: Italic consisting of a one-time subsequent period of inspection of selected extended operation. Supplement 21, Formatted: Indent: Left: 0.24" components to verify: (a) the Inspections that are Dom-21-075 Formatted: Indent: Left: 0.49" system-wide effectiveness of to be completed prior Mar. 17, 2021, an AMP that is designed to to the subsequent ML21076B025 prevent or minimize aging to period of extended A-29 the extent that it will not cause operation are the loss of intended function completed 6 months during the subsequent period prior to the of extended operation; (b) the subsequent period of insignificance of an aging extended operation effect; and (c) that long-term or no later than the loss of material will not cause last refueling outage a loss of intended function for prior to the steel components exposed to subsequent period of environments that do not extended operation.

include corrosion inhibitors as a preventive action.

The One-Time lnspectionOne-Time Formatted: Font: Italic Inspection grogram program will perform a magnetic particle test inspection of the continuous circumferential transition cone closure weld and the accessible portions of the upper shell-to-transition

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments cone girth weld on each steam generator (essentially.

100% examination coverage of each weld) prior to the subsequent period of extended operation. (Updated

- Supplement 2)

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

21 Selective Leaching XI.M33 The Selective Leaching B2.1.21 Program will be Application, Review Complete -Added NUREG-2191 Section program program is a new condition implemented and Aug. 24, 2020, monitoring program that will inspections begin 10 Dom-20-115, monitor components years before the ML20246G703 constructed of materials subsequent period of which are susceptible to extended operation.

selective leaching. The Inspections that are A-30 selective leaching program to be completed prior includes a one-time to the subsequent inspection for susceptible period of extended components exposed to operation are closed cycle cooling water completed 6 months and treated water prior to the environment since subsequent period of plant-specific operating extended operation experience has not revealed or no later than the selective leaching in these last refueling outage environments, as well as prior to the opportunistic and periodic subsequent period of inspections for susceptible extended operation.

components exposed to raw water, waste water, and soil (which may include groundwater) environments.

Industry and plant-specific operating experience will be evaluated in the development

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments and implementation of this program.

22 ASME Code Class 1 XI.M35 The ASME Code Class 1 B2.1.22 Program will be Application, Review Complete -Added NUREG-2191 Section Small-Bore Piping Small-Bore Piping program is implemented and Aug. 24, 2020, program a new condition monitoring inspections are Dom-20-115, program that augments the completed within 6 ML20246G703 existing ASME Code, years before the Section XI requirements and subsequent period of is applicable to ASME Code extended operation.

Class 1 small-bore piping and Inspections that are systems with a NPS diameter to be completed prior less than 4 inches and greater to the subsequent than or equal to 1 inch. This period of extended program provides for operation are volumetric examination of a completed 6 months sample of full penetration prior to the (butt) welds and partial subsequent period of penetration (socket) welds in extended operation Class 1 piping to manage or no later than the cracking due to stress last refueling outage A-31 corrosion cracking or thermal prior to the or vibratory fatigue loading. subsequent period of Volumetric examinations will extended operation.

employ techniques that have been demonstrated to be capable of detecting flaws and discontinuities in the examination volume of interest.

The extent and schedule for volumetric examination is based on plant-specific operating experience and whether actions have been implemented that effectively mitigate the cause(s) of any past cracking. The program provides for a one-time inspection of a sample of the population of welds (butt welds or socket welds) for

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments plants that have not experienced cracking or have experienced cracking but have implemented corrective actions, such as a design change, to effectively mitigate the cause(s) of the cracking.

The program provides for periodic inspection of a sample of the population of welds (butt welds or socket welds) that have experienced cracking and have not implemented corrective actions to effectively mitigate the cause(s) of the cracking.

Industry and plant-specific operating experience will be evaluated in the development A-32 and implementation of this program.

23 External Surfaces XI.M36 The External Surfaces B2.1.23 Program Application, Review Complete -Added NUREG-2191 Section Monitoring of Monitoring of Mechanical enhancements for Aug. 24, 2020, Mechanical Components program is an SLR will be Dom-20-115, Components program existing condition monitoring implemented 6 ML20246G703 program that will be enhanced months prior to the as follows: subsequent period of extended operation.

1. Procedures will be revised to specify walkdowns will be performed at a frequency not to exceed one refueling cycle.

Since some surfaces are not readily visible during both plant operations and refueling outages, surfaces will be inspected when they are made accessible and at intervals that ensure the components' intended functions are maintained.

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

2. Procedures will be revised to specify that visual inspections of elastomers and flexible polymers will cover 100% of accessible component surfaces. The minimum surface area for tactile inspections of elastomers and flexible polymers will be at least 10%

of the accessible surface area.

3. A new procedure will be developed to specify the following to manage cracking of stainless steel, nickel-alloy, and copper alloy (>15% Zn) components and cracking and A-33 loss of material of insulated outdoor/indoor components exposed to condensation populations:

a. In each 10-year period during the subsequent period of extended operation, the minimum number of inspections is completed.

Inspections for cracking will be performed from each of the stainless steel, nickel-alloy, and copper alloy

(>15% Zn) component populations every 10 years.

Examinations are conducted on 20% of the surface area unless the component is measured in linear feet, such as piping. Alternatively, any combination of a minimum of

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments 25 one-foot axial length sections and components is inspected. In addition, for each unit, both the inner and outer nickel-alloy reactor vessel flange leakage monitor tubes will be inspected every 10 years. For insulated outdoor components and indoor components exposed to condensation, following insulation removal, a minimum of 20% of the in-scope piping length, or 20% of the surface area for components whose configuration does not conform to a one-foot axial length determination is inspected for loss of material A-34 and cracking. Alternatively, any combination of a minimum of 25 one-foot axial length sections and components for each material type is inspected. The new procedure will specify that the inspections focus on the components most susceptible to aging because of time in service, severity of operating conditions, and lowest design margin.

b. Additional inspections will be performed if any sampling-based inspections to detect cracking in stainless steel, nickel-alloy, and copper alloy (>15% Zn) components do not meet the acceptance criteria, unless the cause of

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments the aging effect for each applicable material and environment is corrected by repair or replacement. There will be no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20% of each applicable material, environment, and aging effect combination inspected, whichever is less.

If any subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis will be conducted to determine the further extent of inspections required.

Additional samples will be A-35 inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. The additional inspections will include inspections of components with the same material, environment, and aging effect combination at both Unit 1 and Unit 2. The additional inspections will be completed within the interval (e.g., refueling outage interval, 10-year inspection interval) in which the original inspection was conducted.

4. Procedures will be revised to evaluate and project the rate of degradation until the end of the subsequent period

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments of extended operation or the next scheduled inspection, whichever is shorter. The inspection sampling bases (e.g., selection, size, frequency) will be adjusted as necessary based on the projection.

5. Procedures will be revised to specify that, where practical, acceptance criteria are quantitative (e.g.,

minimum wall thickness). For quantitative analyses, the required minimum wall thickness to meet applicable design standards will be used.

For qualitative evaluations, applicable parameters such A-36 as ductility, color, and other indicators will be addressed to ensure a decision is based on observed conditions.

24 Flux Thimble Tube XI.M37 The Flux Thimble Tube B2.1.24 Ongoing Application, Review Complete -Added NUREG-2191 Section Inspection program Inspection program is an Aug. 24, 2020, existing condition monitoring Dom-20-115, program that is credited. ML20246G703 25 Inspection of Internal XI.M38 The Inspection of Internal B2.1.25 Program Application,

Review Complete -Added NUREG-2191 Surfaces in Surfaces in Miscellaneous enhancements for Aug. 24, 2020, Section Miscellaneous Piping Piping and Ducting SLR will be Dom-20-115,

Formatting - In Item 1, separated bullets..

and Ducting Components program is an implemented 6 ML20246G703

Deleted reference to Dominion letter number Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

Components program existing condition monitoring months prior to the in Commitment text program that will be enhanced subsequent period of RAI Set 3 Aligned at: 0.25" + Indent at: 0.5" as follows: extended operation. Response, Dom-21-184, May

1. Procedures will be revised 27, 2021, to require inspection of ML21147A293 elastomeric and flexible polymeric components for the following:

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

Surface crazing, scuffing, loss of sealing, blistering, and dimensional change (e.g.,

ballooning and necking)

Loss of wall thickness

Exposure of internal reinforcement (e.g.,

reinforcing fibers, mesh, or underlying metal) for reinforced elastomers

2. Procedures will be revised to specify that visual inspection of elastomeric and flexible polymeric components is supplemented by tactile inspection to detect hardening or loss of suppleness. The minimum surface area for tactile inspections will be at A-37 least 10% of the accessible surface area.

3. Procedures will be revised to specify that follow-up volumetric examinations are performed where irregularities that could be indicative of an unexpected level of degradation are detected for steel components exposed to raw water, raw water (potable), or waste water.

4. Procedure(s) will be revised or developed to specify the following:

a. In each 10-year period during the subsequent period of extended operation, the minimum number of

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments inspections is completed for the various sample populations (each material, environment, and aging effect combination). If opportunistic inspections will not fulfill the minimum number of inspections by the end of each 10-year period, the program owner will initiate work orders as necessary to request additional inspections. A representative sample of 20% of the population (defined as components having the same material, environment, and aging effect combination) or a maximum of 19 components per population at each unit A-38 will be inspected. The new procedure will specify that the inspections focus on the bounding or lead components most susceptible to aging due to time in service and severity of operating conditions.

b. The rate of degradation will be evaluated and projected until the end of the subsequent period of extended operation or the next scheduled inspection, whichever is shorter. The inspection sampling bases (e.g., selection, size, frequency) will be adjusted as necessary based on the projection.

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

{Deleted duplicate text - RAI Set 3)

c. Additional inspections will be performed if any sampling-based inspections do not meet the acceptance criteria, unless the cause of the aging effect for each applicable material and environment is corrected by repair or replacement. There will be no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20% of each applicable material, environment, and aging effect combination are inspected, whichever is less.

If any subsequent inspections A-39 do not meet acceptance criteria, an extent of condition and extent of cause analysis will be conducted to determine the further extent of inspections required.

Additional samples will be inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. The additional inspections will include inspections of components with the same material, environment, and aging effect combination at both Unit 1 and Unit 2. The additional inspections will be completed within the interval (e.g., refueling outage interval, 10-year inspection

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments interval) in which the original inspection was conducted or, if identified in the latter half of the current inspection interval, within the next refueling outage interval. These additional inspections conducted in the next inspection interval cannot also be credited towards the number of inspections in the latter interval.

5. The existing inspections of the Unit 1 and Unit 2 bearing cooling system, performed under the Corrective Action Program, will be enhanced to require performance of a minimum of 10 piping wall A-40 thickness measurements at each Unit with a frequency not to exceed two refueling cycle intervals. Locations with a wall thickness of less than 50% will be selected and augmented as necessary considering prior inspection results, extent of degradation, rate of degradation, and timing of the next inspection.

(Renumbered - RAI Set 3)

6. Procedure(s) will be revised or developed to specify that, where practical, acceptance criteria are quantitative (e.g., minimum wall thickness). For quantitative analyses, the required minimum wall thickness to meet applicable

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments design standards will be used.

For qualitative evaluations, applicable parameters such as ductility, color, and other indicators will be addressed to ensure a decision is based on observed conditions.

(Renumbered - RAI Set 3) 26 Lubricating Oil XI.M39 The Lubricating Oil Analysis B2.1.26 Ongoing Application, Review Complete -Added NUREG-2191 Section Formatted: Font color: Red Analysis program program is an existing Aug. 24, 2020, preventive program that is Dom-20-115, credited. ML20246G703 27 Buried and XI.M41 The Buried and Underground B2.1.27 Program will be Application,

Review Complete -Added NUREG-2191 Underground Piping Piping and Tanks program is implemented and Aug. 24, 2020, Section and Tanks program an existing condition inspections begin 10 Dom-20-115,

Added introductory sentence. Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

monitoring program that will years before the ML20246G703

Replaced period with colon on 2.

be enhanced as follows: subsequent period of Aligned at: 0.25" + Indent at: 0.5"

Deleted (Added - Supplement 1) from 3.

1. Procedures will be revised extended operation. Supplement 1,

Deleted and five of the inspections at each to obtain pipe-to-soil potential Inspections that are Feb. 4, 2021, unit destructively examine the from 5.

measurements for piping in to be completed prior Dom-20-416, A-41

Deleted Program and Tanks from 5.

the scope of SLR during the to the subsequent ML21035A303

Deleted on a one foot length (minimum) next soil survey within 10 period of extended piping section from each discrete excavation years prior to entering the operation are RAI Set 4 location (five/unit) from 5.

subsequent period of completed 6 months Response and

Replaced insQect with inspect in 5.

operation. prior to the Supplement 3,

Deleted (Added - Supplement 3)(Revised subsequent period of Dom-21-213, Jul.

Supplement 4) from 5.

2. The following service water extended operation 29, 2021, CP subsystems will be or no later than the ML21210A396

Replaced backfit with backfill in 5.

refurbished and reconnected last refueling outage

Added two commas at cyclic loading before the last five years of prior to the Supplement 4, conditions in 5.

the inspection period prior to subsequent period of Dom-21-280,

Replaced excavation with excavated in 6.

entering the subsequent extended operation. Aug. 26, 2021,

Deleted (Added - Supplement 4) in 6.

period of extended operation:. ML21238A297

Replaced garticle with particle in 6.b.

Replaced radiograghic with radiographic

a. The service water D CP in 6.b.

subsystem

Replaced NOE with NDE in 6.b & 6.c.

Deleted '. From 6.c.

b. The service water C CP

Deleted comma in 6.c.

subsystem associated with

Replaced fof with of in 6.e.

the buried carbon steel piping

Replaced basis with base in 6.e.

of the fuel oil system for the

Replaced protected with projected in 6.e.

Formatted: Indent: Left: 0.24"

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments emergency electrical power system

3. 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.

b. The buried carbon steel fill line piping for the security diesel fuel oil tank will be A-42 replaced with corrosion resistant material that does not require inspection (e.g.,

titanium alloy, super austenitic, or nickel alloy materials).

4. Procedures will be revised to specify that cathodic protection surveys use the -850 mV polarized potential, instant off criterion specified in NACE SP0169-2007 for steel piping acceptance criteria unless a suitable alternative polarization criteria can be demonstrated. Alternatives will include the -100 mV polarization criteria, -750 mV criterion (soil resistivity is greater than 10,000 ohm-cm

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments to less than 100,000 ohm-cm), -650 mV criterion (soil resistivity is greater than 100,000 ohm-cm), or verification of less than 1 mpy loss of material rate. Program will be implemented and

a. The external loss of inspections begin 10 material rate is verified:

year before the Every year when verifying the subsequent period of effectiveness of the cathodic extended operation .

protection system by lnspections that are measuring the loss of material to be comgleted prior rate.

Every 2 years when to the subsequent using the 100 mV minimum period of extended polarization.

Every 5 years ogeration are when using the -750 or -650 completed 6 months mV criteria associated with prior to the higher resistivity soils. The subsequent period of soil resistivity is verified every extended operation A-43 5 years. or no later than the last refueling outage

b. As an alternative to prior to the verifying the effectiveness of subsequent period of the cathodic protection extended operation.

system every five years, soil resistivity testing is conducted annually during a period of time when the soil resistivity would be expected to be at its lowest value (e.g., maximum rainfall periods). Upon completion of ten annual consecutive soil samples, soil resistivity testing can be extended to every five years if the results of the soil sample tests consistently have verified that the resistivity did not fall outside of the range being credited (e.g., for the -750 mV relative to a

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments CSE, instant off criterion, measured soil resistivity values were greater than 10,000 ohm-cm).

c. When using the electrical resistance corrosion rate probes:

The individual determining the installation of the probes and method of use will be qualified to NACE CP4, Cathodic Protection Specialist or similar

The impact of significant site features and local soil conditions will be factored into placement of the probes and use of the data

5. Procedures will be revised A-44 to require a minimum of six excavations be conducted at each unit to inspect for loss of material due to selective leaching in and five of the inspections at each unit destructively examine the buried gray cast iron fire protection piping and piping components. The inspections will be conducted in the 10-year period prior to the subsequent period of extended operation and in each 10-year period during the subsequent period of extended operation. A ten-foot pipe length will be excavated for each buried grey cast iron fire protection piping sample and the external surfaces inspected

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments for blistering, cracking, hardening or loss of strength, and loss of material.

Additionally NUREG-2191 Section XI.M33 Selective Leaching Program and Tanks program destructive examinations will be conducted on a one-foot length of fire protection system piping or a different component type from each discrete inspection location (six/unit) on a one foot length (minimum) piping section from each discrete excavation location (five/unit) to inspQect for loss of material due to selective leaching. Five of the A-45 inspections will be conducted on a one-foot length of fire protection piping and the sixth inspection will be conducted on either a one-foot length of piping from the fire protection system or a different component type (e.g., hydrant) from the fire protection system. The selection of inspection locations for buried gray cast iron fire protection piping and piping components will consider the following criteria:

(Added -

Supplement 3)(Revised Supplement 4)

Older piping segments (i .e.

not previously replaced)

Piping and piping components found to be continuously

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments wetted due to leaking piping/valves or in soil with high corrosivity ratings as determined by EPRI Report 3002005294, Soil Sampling and Testing Methods to Evaluate the Corrosivity of the Environment for Buried Piping and Tanks at Nuclear Power Plants

Piping and piping components not cathodically protected

Piping and piping components with significant coating degradation or unexpected backfillt

Consequence of failure (i.e.,

proximity to safety-related piping and piping A-46 components)

Locations with potentially high stress and/or cyclic loading conditions such as piping adjacent to locations that were replaced due to cracking/rupture, locations subject to settlement, or locations subject to heavy load traffic

6. Procedures will be revised to require five excavatedion piping samples at each unit be inspected (internally and externally) for cracking due to cyclic loading. The inspections will be conducted in the 10-year period prior to the subsequent period of extended operation (SPEO) and in each 10-year period

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments during the SPEO as follows:

(Added - Supplement 4)

a. A 10-foot piping length of buried gray iron fire protection piping will be excavated for each inspection.

b. Visual (VT) and magnetic pgarticle (MT) examinations will be conducted on the 10-foot buried gray cast iron fire protection piping samples.

The radiograpghic (RT) nondestructive examination (NDOE) method will be applied to areas that have potential surface cracking identified using the MT method.

c. Examination results will be evaluated by a Level II or Ill A-47 examiner qualified to ASME Code,Section XI and the following performed, as applicable:

If there is no cracking identified using the NDOE techniques, then a one-foot axial piece of the fire protection piping sample will still be removed and destructively'. examined to inspect for the loss of material due to selective leaching as required by NUREG-2191 Section XI.M33 Selective Leaching program (see Enhancement 5).

If cracking is identified then a bounding one-foot axial section of the fire protection piping sample will be selected based on the crack size and

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments characterization determined by a qualified NDOE Level II or Ill examiner and further destructive examination conducted to identify, cracking due to cyclic loading.

The destructive examination of the one-foot axial section will also be inspected for the loss of material due to selective leaching (see Enhancement 5).

d. If results of the destructive examination inspections determine the cracking is due to cyclic loading, then Engineering will perform a crack growth evaluation and a flaw stability evaluation based on the predicted crack lengths A-48 at the end of the SPEO.

e. If results of the evaluations indicate the depth or extent of cracking fof the baseis metal is projtected to cause loss of intended function prior to the end of the SPEO Engineering will perform an evaluation to determine the extent of condition. extent of cause and the need for further follow-on actions through the Corrective Action Program (e.g.,

additional inspections).

28 Internal XI.M42 The Internal Coatings/Linings B2.1.28 Program will be Application,

Review Complete -Added NUREG-2191 Coatings/Linings for for In-Scope Piping, Piping implemented and Aug. 24, 2020, Section In-Scope Piping, Components, Heat inspections begin 10 Dom-20-115,

Deleted references to Dominion letters in Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

Piping Components, Exchangers, and Tanks years before the ML20246G703 Commitment text Heat Exchangers, program is an existing subsequent period of Aligned at: 0.25" + Indent at: 0.5" and Tanks program condition monitoring program extended operation. Supplement 1, that will be enhanced as Inspections that are Feb. 4, 2021, follows: to be completed prior

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments to the subsequent Dom-20-416,

1. Procedures will be revised period of extended ML21035A303 to require baseline operation are inspections (100% of completed 6 months accessible coatings/linings) of prior to the the following tanks, piping, subsequent period of and miscellaneous extended operation components within the scope or no later than the of subsequent license last refueling outage renewal and inspection prior to the intervals will not exceed those subsequent period of specified in NUREG-2191 extended operation.

Table XI.M42-1, Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers:

(Revised - Supplement 1)

Condensate polishing Powdex tanks A-49

Pressurizer relief tanks

Chilled water mechanical chiller cooler (channel head)

Circulating water inlet and outlet waterbox distributors

Fire protection isolation valve

Drains - bldg. services piping

2. Procedures will be revised to include as an alternative to repair, rework, or removal, internal coatings/linings exhibiting indications of peeling and delamination. The component may be returned to service if:

a. Physical testing is conducted to ensure that the

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments remaining coating is tightly bonded to the base metal,

b. the potential for further degradation of the coating is minimized, (i.e., any loose coating is removed, the edge of the remaining coating is feathered),

c. adhesion testing using ASTM International Standards endorsed in RG 1.54 (e.g.,

pull-off testing, knife adhesion testing) is conducted at a minimum of three sample points adjacent to the defective area,

d. an evaluation is conducted A-50 of the potential impact on the system, including degraded performance of downstream components due to flow blockage and loss of material or cracking of the coated component, and

e. follow-up visual inspections of the degraded coating are conducted within two years from detection of the degraded condition, with a re-inspection within an additional two years, or until the degraded coating is repaired or replaced.

3. Procedures will be revised to require additional inspections be conducted if one of the inspections does

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments not meet acceptance criteria due to current or projected degradation (i.e., trending) unless the cause of the aging effect for each applicable material and environment is corrected by repair or replacement of components constructed of the same material and exposed to the same environment. The number of increased inspections will be determined in accordance with the Corrective Action Program.

However, there are no fewer than five additional inspections or each inspection that did not meet acceptance criteria, or 20% of each A-51 applicable material, environment, and aging effect combination inspected, whichever is less. When inspections are based on the percentage of piping length, an additional 5% of the total length will be inspected. The timing of the additional inspections will be based on the severity of the degradation identified and will be commensurate with the potential for loss of intended function. However, in all cases, the additional inspections will be completed within the interval in which the original inspection was conducted, or if identified in the latter half of the current inspection interval, within the

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments next refueling outage interval.

These additional inspections conducted in the next inspection interval cannot also be credited towards the number of inspections in the latter interval. If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis will be conducted to determine the further extent of inspections.

Additional samples will be inspected for any recurring degradation to provide reasonable assurance that corrective actions appropriately address the associated causes. The A-52 additional inspections will include inspections with the same material, environment, and aging effect combination at Unit 1 and Unit 2.

4. Procedures will be revised to require inspection frequencies for internal coatings/linings of in-scope piping and piping components are performed on a frequency consistent with Table XI.M42-1, various frequencies from 4-12 years.

29 ASME Section XI, XI.S1 The ASME Section XI, B2.1.29 Program Application, Review Complete -Added NUREG-2191 Section Subsection IWE Subsection IWE program is enhancements are Aug. 24, 2020, program an existing condition implemented 6 Dom-20-115, monitoring program that will months prior to the ML20246G703 be enhanced as follows: subsequent period of extended operation Supplement 1, and if triggered by Feb. 4, 2021,

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

1. Procedures will be revised plant-specific Dom-20-416, to augment visual operating experience, ML21035A303 examinations with surface a one-time examinations (or other supplemental applicable technique, (e.g., volumetric EVT-1) to manage cracking in examination by the Containment pressure sampling randomly retaining portions of the fuel selected as well as transfer tube, fuel transfer focused locations tube enclosure, fuel transfer susceptible to loss of tube blind flange, dissimilar thickness due to metal weld penetrations, and corrosion of high-temperature piping containment shell or penetrations. Surface liner that is examinations will be inaccessible from one performed once during each side is completed 6 10-year interval. months prior to the (Revised - Supplement 1) subsequent period of extended operation

2. Procedures will be revised or no later than the A-53 to perform a one-time last refueling outage volumetric examination of prior to the metal liner surfaces that are subsequent period of inaccessible from one side at extended both units if triggered by operation.

plant-specific operating experience. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal liner corrosion (base metal material loss exceeding 10%

of nominal plate thickness) at either unit initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments include both randomly-selected and focused areas most likely to experience degradation based on operating experience and/or other relevant considerations such as environment. The supplemental volumetric examinations for each unit will occur within two refueling outages after identifying the trigger for the examination.

Any identified degradation is addressed in accordance with the applicable provisions of the ASME Section XI, Subsection IWE program. The sample size, locations, and any needed scope expansion A-54 (based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95%

confidence that 95% of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 10% loss of nominal thickness. There has been no triggering plant-specific operating experience at either unit since the date of issuance of the first renewed licenses.

(Revised - Supplement 1)

3. Plant procedures will be revised to specify that

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments successive inspections will be sequenced, evaluated, and re-examined in accordance with ASME Code,Section XI, Subsection IWE, Article IWE-2420. Examination results will be compared with recorded results of prior inservice examinations and evaluated for acceptance in accordance with ASME Code,Section XI, Subsection IWE, Article IWE-3120.

30 ASME Section XI, XI.S2 The ASME Section XI, B2.1.30 Ongoing Application, Review Complete -Added NUREG-2191 Section Subsection IWL Subsection IWL program is an Aug. 24, 2020, program existing condition monitoring Dom-20-115, program that is credited. ML20246G703 31 ASME Section XI, XI.S3 The ASME Section XI, B2.1.31 Program will be Application,

Review Complete -Added NUREG-2191 Subsection IWF Subsection IWF program is implemented and a Aug. 24, 2020, Section program an existing condition one-time inspection Dom-20-115,

Deleted completed Item 4 and associated A-55 monitoring program that will of an additional 5% of ML20246G703 note as reflected in Supplement 1.

be enhanced as follows:ws: the sample size

Corrected ML number on RAI Set 1 specified in Supplement 1,

Minor edit in the introductory text Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

1. Procedures will be revised Table IWF-2500-1 for Feb. 4, 2021, to evaluate the acceptability Class 1, 2, and 3 Dom-20-416, Aligned at: 0.25" + Indent at: 0.5" of inaccessible areas (e.g., piping supports is ML21035A303 portions of supports encased conducted within 5 in concrete, buried years prior to the RAI Set 1 underground, or encapsulated subsequent period of Response, by guard pipe) when extended operation, Dom-21-074, conditions exist in accessible and are to be Apr. 1, 2021, areas that could indicate the completed prior to the ML21091A1876 presence of, or result in, subsequent period of degradation to such extended operation, inaccessible areas. are completed 6 months prior to the

2. Procedures will be revised subsequent period of to specify that, for extended operation high-strength bolting greater or no later than the than one inch nominal last refueling outage diameter within the scope of prior to the the ASME Section XI,

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments Subsection IWF program, subsequent period of volumetric examination extended operation.

comparable to that of ASME Code,Section XI, Table IWB-2500-1, Examination Category B-G-1 will be performed to detect cracking in addition to the VT-3 examination. In each 10-year period during the subsequent period of extended operation, a representative sample of 20%

of the population or a maximum of 19 high-strength bolts per unit will be inspected for IWF supports located in an air environment.

3. Procedures will be revised A-56 to specify a one-time inspection within five years prior to entering the subsequent period of extended operation of an additional 5% of the sample populations for Class 1, 2, and 3 piping supports. The additional supports will be selected from the remaining population of IWF piping supports and will include components that are most susceptible to age-related degradation.

4. Procedures will be revised to require that if a component support does not exceed the acceptance standards of IWF-3400 but is repaired to as-new condition, the sample is

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments increased or modified to include another support that is representative of the remaining population of supports that were not repaired.

(Completed - Supplement 1) 32 10 CFR 50, Appendix XI.S4 The 10 CFR 50, Appendix J B2.1.32 Ongoing Application, Review Complete -Added NUREG-2191 Section J program program is an existing Aug. 24, 2020, condition monitoring program Dom-20-115, that is credited. ML20246G703 33 Masonry Walls XI.S5 The Masonry Walls program B2.1.33 Ongoing Application, Review Complete -Added NUREG-2191 Section program is an existing condition Aug. 24, 2020, monitoring program that is Dom-20-115, credited. ML20246G703 34 Structures Monitoring XI.S6 The Structures B2.1.34 Program Application,

Review Complete -Added NUREG-2191 program MonitoringStructures enhancements for Aug. 24, 2020, Section Formatted: Font: Italic Monitoring program Is an SLR will be Dom-20-115,

To be consistent throughout the table, the existing condition monitoring implemented 6 ML20246G703 name of the program should be in italics in program that will be enhanced months prior to the the Commitment column A-57 as follows: subsequent period of RAI Set 1

Corrected ML number for RAI Set 1 extended operation. Response,

Deleted Dominion letter numbers in

1. Procedures will be revised Dom-21-074, Commitment text to include inspection of the Apr. 1, 2021,

Minor edits following structures that are ML21091A186 Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

within the scope of ML21091A187 Aligned at: 0.25" + Indent at: 0.5" subsequent license renewal:

Administration Building (aka Office Building),

Decontamination Building, Domestic Water Treatment Building, Heater Boiler Room, Maintenance Building, New Fuel Receiving Building, Waste Disposal (Clarifier)

Building, Waste Solids Building, 17-ton Carbon Dioxide tank foundation, and Backup 34.5 kV Circuit Power Poles (Switchyard to the Reserve Station Service Transformers). Baseline

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments inspections for the added structures will be performed under the enhanced program in order to establish quantitative inspection data prior to conduct of periodic inspections in the subsequent period of extended operation.

The baseline inspections will include baseline inspections of the masonry walls in the Administration Building, Decontamination Building, Domestic Water Treatment Building, and the Maintenance Building.

2. Procedures will be revised to specify that structural components inspected A-58 include structural bolting, anchor bolts and embedments, component support members, pipe whip restraints and jet impingement shields, transmission towers, panels and other enclosures, racks, sliding surfaces, sump and pool liners, electrical cable trays and conduits, tube tracks, trash racks associated with water-control structures, electrical duct banks, manholes, doors, penetration seals, seismic joint filler and other elastomeric materials.

3. Procedures will be revised to specify that aluminum and stainless steel structural components such as louvers, cable trays, conduits, and

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments structural supports will be monitored for loss of material and cracking due to SCC that could lead to the reduction or loss of their intended function.

(Revised - RAI Set 1)

4. Procedures will be revised to specify that elastomeric vibration isolators, structural sealants, and seismic joint fillers will be monitored for cracking, loss of material, and hardening that could lead to the reduction or loss of their intended function. Visual inspection of elastomeric elements is supplemented by tactile inspection to detect hardening if the intended A-59 function is suspect.

5. Procedures will be revised to specifically specify that the carbon fiber reinforced golJ'.merpolymer (CFRP) wrag wrap of the concrete gales poles for the reserve station service transformer (RSST) tube bus will be monitored for hardening or loss of strength, loss of material, cracking or blistering that could lead to the reduction or loss of intended function .function. (Added -

RAI Set 1)

6. Procedures will be revised to specify that accessible sliding surfaces will be monitored for indications of

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments excessive loss of material due to corrosion or wear and debris or dirt that could restrict or prevent sliding of the surfaces. (Renumbered -

RAI Set 1)

7. Procedures will be enhanced to specify that evaluations of neutron shield tank findings consider its structural support function for the reactor pressure vessel.

(Renumbered - RAI Set 1) 35 Inspection of XI.S7 The Inspection of B2.1.35 Program Application, Review Complete -Added NUREG-2191 Section Water-Control Water-Control Structures enhancements for Aug. 24, 2020, Structures Associated Associated with Nuclear SLR will be Dom-20-115, with Nuclear Power Power Plants program is an implemented 6 ML20246G703 Plants program existing condition monitoring months prior to the program that will be enhanced subsequent period of A-60 as follows: extended operation.

1. Procedures will be revised to include the Circulating Water Intake Tunnel Header and the Discharge Tunnel Seal Pit within the scope of the program.

2. Procedures will be revised to specify underwater inspections or dewatering to permit visual inspections for submerged structures, on a frequency not to exceed five years.

36 Protective Coating XI.S8 The Protective Coating B2.1.36 Ongoing Application, Review Complete -Added NUREG-2191 Section Monitoring and Monitoring and Maintenance Aug. 24, 2020, Maintenance program program is an existing Dom-20-115, mitigative and condition ML20246G703 monitoring program that is credited.

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments 37 Electrical Insulation XI.E1 The Electrical Insulation for B2.1.37 Program Application, Review Complete -Added NUREG-2191 Section for Electrical Cables Electrical Cables and enhancements for Aug. 24, 2020, and Connections Not Connections Not Subject to SLR will be Dom-20-115, Subject to 10 CFR 50.49 Environmental implemented 6 ML20246G703 10 CFR 50.49 Qualification Requirements months prior to the Environmental program is an existing subsequent period of Qualification condition monitoring program extended operation.

Requirements that will be enhanced as program follows:

1. Procedures will be revised to add the requirement to identify adverse localized environments through plant operational experience reviews, communication with maintenance, operations, and radiation protection personnel, and the use of environmental surveys for A-61 determining each of the most limiting cable and connection electrical insulation plant environments (e.g., caused by temperature, radiation, moisture, or contamination.)

2. Procedures will be revised to add a list of structures/areas to perform/conduct the visual inspections of cables and connections.

3. Procedures will be revised to add the requirement to perform a review of previously identified and mitigated adverse localized environments cumulative aging effects applicable to in-scope cable and

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments connection electrical insulation.

4. Procedures will be revised to add a description of testing methodology: Should testing be deemed necessary based on unacceptable visual indications of surface anomalies, a sample size of 20% of each cable and connection insulation material type found within the adverse localized environment with a maximum sample size of 25 will be tested. The following factors will be considered in the development of the cable and connection insulation test sample: environment A-62 including identified adverse localized environments (high temperature, high humidity, vibration, etc.), voltage level, circuit loading, connection type, location (high temperature, high humidity, vibration, etc.), and insulation material. Testing may include thermography and other proven condition monitoring test methods applicable to the cable and connection insulation. Testing as part of an existing maintenance, calibration or surveillance program may be credited. The technical basis for the sample selected is provided.

5. Procedures will be revised to add the requirement that if

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments anomalies are found during the visual inspection process, they will be addressed through the Corrective Action Program.

6. Procedures will be revised to add the requirement to verify that the test results for electrical cable and connection insulation material are to be within the acceptance criteria, as identified in the procedures.

7. Procedures will be revised to add the requirement to include the performance of an Engineering evaluation of unacceptable test results and A-63 visual indications of cable and connection electrical insulation abnormalities. The evaluation will consider the age and operating environment of the component, as well as the severity of the abnormality and whether such an abnormality has previously been correlated to degradation of cable or connection insulation.

Corrective actions include, but are not limited to, testing, shielding, or otherwise mitigating the environment or relocation or replacement of the affected cables or connections. When an unacceptable condition or situation is identified, a

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments determination is made as to whether the same condition or situation is applicable to additional in-scope accessible and inaccessible cables or connections (extent of condition).

38 Electrical Insulation XI.E2 The Electrical Insulation for B2.1.38 Program Application, Review Complete -Added NUREG-2191 Section for Electrical Cables Electrical Cables and enhancements for Aug. 24, 2020, and Connections Not Connections Not Subject to SLR will be Dom-20-115, Subject to 10 CFR 50.49 Environmental implemented 6 ML20246G703 10 CFR 50.49 Qualification Requirements months prior to the Environmental Used in Instrumentation subsequent period of Qualification Circuits program is an existing extended operation.

Requirements Used condition monitoring program in Instrumentation that will be enhanced as Circuits program follows:

1. A new procedure will be developed to add testing of A-64 the post-accident neutron monitoring system cables and connections external to Containment to the Program.

The procedure will evaluate reduced electrical insulation resistance by measuring cable resistance and capacitance.

2. The Nuclear Instrumentation test procedures will be enhanced to specify the acceptance criteria.

3. Procedures will be enhanced to include corrective actions and a requirement for performance of an Engineering evaluation when cable system test

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments results do not meet the acceptance criteria. Results of the Engineering evaluation will determine if the test frequency needs to be increased.

39 Electrical Insulation XI.E3A The Electrical Insulation for B2.1.39 Program Application,

Review Complete -Added NUREG-2191 for Inaccessible Inaccessible Medium-Voltage enhancements for Aug. 24, 2020, Section Medium-Voltage Power Cables Not Subject to SLR will be Dom-20-115,

Enhancements 2-7 can be deleted because Formatted: Indent: Left: -0.01", Bulleted + Level: 1 +

Power Cables Not 10 CFR 50.49 Environmental implemented 6 ML20246G703 they were documented as completed in Subject to Qualification Requirements months prior to the Aligned at: 0.25" + Indent at: 0.5" Supplement 1 10 CFR 50.49 program is an existing subsequent period of Supplement 1, Environmental condition monitoring program extended operation. Feb. 4, 2021, Qualification that will be enhanced as Dom-20-416, Requirements follows: ML21035A303 program

1. Procedures will be revised to inspect and dewater, if required, the in-scope manholes after event driven A-65 occurrences, such as heavy rain, rapid thawing of ice and snow, or flooding.

2. Procedures will be revised to add a step stating that automatic or passive drainage features of manholes are operating properly.

(Completed - Supplement 1)

3. Procedures will be revised to add a step that includes a requirement for testing medium-voltage cables that are exposed to significant moisture to determine the condition of the electrical insulation.

(Completed - Supplement 1)

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments

4. Procedures will be revised to add cables from RSST `B' and `C' to Bus 1G and Bus 2G, and associated handholes, to the scope of the program and perform inspections, dewatering, and testing with the first inspection scheduled prior to the subsequent period of extended operation.

(Completed - Supplement 1)

5. Procedures will be revised to add a step to evaluate adjusting the inspection frequency of manholes based on plant-specific operating experience over time with water collection.

A-66 (Completed - Supplement 1)

6. A plant-specific inaccessible medium-voltage cable test matrix will be created that documents inspection methods, test methods, and acceptance criteria for the in-scope inaccessible medium-voltage power cables based on OE.

Testing will be conducted at least every six years.

(Completed - Supplement 1)

7. Procedures will be revised to include a requirement to review visual inspection and physical test results that are trendable and repeatable to provide additional information on the rate of cable or

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments connection insulation degradation.

(Completed - Supplement 1) 40 Electrical Insulation XI.E.3B The Electrical Insulation for B2.1.40 Program will be Application, Review Complete -Added NUREG-2191 Section for Inaccessible Inaccessible Instrument and implemented 6 Aug. 24, 2020, Instrument and Control Cables Not Subject to months prior to the Dom-20-115, Control Cables Not 10 CFR 50.49 Environmental subsequent period of ML20246G703 Subject to Qualification Requirements extended operation.

10 CFR 50.49 program is a new condition Environmental monitoring program that will Qualification manage the effects of Requirements reduced electrical insulation program resistance or degraded dielectric strength of non-EQ, in scope, inaccessible (e.g.,

installed in buried conduits, cable trenches, cable troughs, duct banks, underground vaults, or direct buried installations), instrument and A-67 control cables, exposed to significant moisture.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

41 Electrical Insulation XI.E3C The Electrical Insulation for B2.1.41 Program will be Application, Review Complete -Added NUREG-2191 Section for Inaccessible Inaccessible Low-Voltage implemented 6 Aug. 24, 2020, Low-Voltage Power Power Cables Not Subject to months prior to the Dom-20-115, Cables Not Subject to 10 CFR 50.49 Environmental subsequent period of ML20246G703 10 CFR 50.49 Qualification Requirements extended operation.

Environmental program is a new condition Qualification monitoring program that will Requirements manage the effects of program reduced electrical insulation resistance or degraded dielectric strength of non-EQ, in scope, inaccessible (e.g.,

installed in buried conduits, cable trenches, cable troughs,

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments duct banks, underground vaults, or direct buried installations), low-voltage power cables (operating voltage less than 2 kV),

exposed to significant moisture.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

42 Metal-Enclosed Bus XI.E4 The Metal-Enclosed Bus B2.1.42 Program Application, Review Complete -Added NUREG-2191 Section program program is an existing enhancements for Aug. 24, 2020, condition monitoring program SLR will be Dom-20-115, that will be enhanced as implemented 6 ML20246G703 follows: months prior to the subsequent period of

1. A new procedure will be extended operation.

A-68 created to add the MEB connecting A Reserve Station Service Transformer to Bus 1G and Bus 2G to the scope of the program and perform inspections and testing on a ten year frequency with the first inspection scheduled prior to the subsequent period of extended operation.

2. Procedures will be revised to add a step for inaccessible sections of bus duct that requires engineering to provide guidance for performance of electrical testing of connections using an ohmmeter and for performance of visual

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments inspection of the bus duct using a borescope.

3. Inspection procedures will be revised to add a note stating that 20% of the accessible bolted connection population, with a maximum of 25, is a representative sample for increased resistance of connection inspections.

4. Procedures will be revised to require the transmittal of bus connection resistance values to engineering for trending to provide information on the rate of connection degradation.

A-69 43 Fuse Holders XI.E5 The Fuse Holders program is B2.1.43 Ongoing Application, Review Complete -Added NUREG-2191 Section program an existing condition Aug. 24, 2020, monitoring program that is Dom-20-115, credited. ML20246G703 44 Electrical Cable XI.E6 The Electrical Cable B2.1.44 Program will be Application, Review Complete -Added NUREG-2191 Section Connections Not Connections Not Subject to implemented 6 Aug. 24, 2020, Subject to 10 CFR 50.49 Environmental months prior to the Dom-20-115, 10 CFR 50.49 Qualification Requirements subsequent period of ML20246G703 Environmental program is a new condition extended operation.

Qualification monitoring program that Requirements consists of a representative program sample of electrical connections tested prior to the subsequent period of extended operation. The results will be evaluated to determine if there is a need for subsequent periodic testing on a 10-year frequency.

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

45 High-Voltage XI.E7 The High-Voltage Insulators B2.1.45 Program will be Application, Review Complete -Added NUREG-2191 Section Insulators program program is a new condition implemented 6 Aug. 24, 2020, monitoring program that months prior to the Dom-20-115, visually inspects high voltage subsequent period of ML20246G703 insulator surfaces and extended operation.

metallic parts at least once Inspections that are every two years initially with to be completed prior the frequency adjusted based to the subsequent on plant specific- operating period of extended experience. For high-voltage operation are insulators that are coated, the completed 6 months visual inspection will be prior to the performed at least once every subsequent period of five years. extended operation or no later than the A-70 Industry and plant-specific last refueling outage operating experience will be prior to the evaluated in the development subsequent period of and implementation of this extended operation.

program.

46 Fatigue Monitoring X.M1 The Fatigue Monitoring B3.1 Program Application, Review Complete -Added NUREG-2191 Section program program is an existing enhancements for Aug. 24, 2020, preventive program that will SLR will be Dom-20-115, be enhanced as follows: implemented 6 ML20246G703 months prior to the

1. Procedures will be revised subsequent period of to require monitoring and extended operation.

tracking of transient cycles associated with the ASME Code,Section XI, Appendix L fatigue sensitive locations to be performed each inspection interval. Consistent with the existing cycle counting program, a surveillance limit will be established to initiate corrective actions prior to

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments exceeding transient cycle assumptions in the ASME Code,Section XI, Appendix L analyses.

2. Procedures will be revised to expand existing corrective action guidance associated with exceeding a cycle counting surveillance limit to recommend consideration of component repair, component replacement, performance of a more rigorous analysis, performance of an ASME Code,Section XI, Appendix L flaw tolerance analysis, or scope expansion to consider other locations with the highest expected CUFen A-71 values.

3. Procedures will be revised to require that when a cycle counting action limit is reached, action will be taken to ensure that the analytical bases of the High-Energy Line Break (HELB) locations are maintained.

47 Neutron Fluence X.M2 The Neutron Fluence B3.2 Ongoing Application, Review Complete -Added NUREG-2191 Section Monitoring program Monitoring program is an Aug. 24, 2020, existing condition monitoring Dom-20-115, program that is credited. ML20246G703 48 Environmental X.E1 The Environmental B3.3 Ongoing Application, Review Complete -Added NUREG-2191 Section Qualification of Qualification of Electric Aug. 24, 2020, Electric Equipment Equipment program is an Dom-20-115, program existing condition monitoring ML20246G703 program that is credited.

49 N/A Procedures will be developed N/A Procedures to RAI Set 1 Review Complete - Updated Implementation to replace the diesel-driven replace the diesel- Response, Schedule to be consistent with RAI Set 4 and fire pump engine heat driven fire pump heat Supplement 3

NUREG-2191 Application Implementation No. Program/Topic SECTION Commitment Section Schedule Source Reviewer Comments exchanger tube bundle on a exchanger tube Dom-21-074, 20-year frequency and require bundle will be in Apr. 1, 2021, the heat exchanger tube place by 12/31/2021. ML21091A186 bundle for the spare engine to Initial replacement of be replaced prior to being the tube bundle for RAI Set 4 placed in-service with the engine #10277066 or Response and diesel-driven fire pump replacement of that Supplement 3, Formatted: Strikethrough (Added - RAI Set 1) (Revised engine with the spare Dom-21-213, Jul.

- Supplement 3) engine will be 29, 2021, completed by ML21210A396 12/31/2025.

Procedures to replace the diesel-driven fire pump heat exchanger tube bundle will be in place 5 years prior to the heat exchanger tube bundle achieving 20 years of A-72 active service.

v t e Letter Sequence Other
EPID:L-2020-SLR-0000, License Renewal (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request Acceptance... Supplement, Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance Meeting, Meeting, Meeting, Meeting, Meeting, Meeting Questions 15 June 2021 23 June 2021 25 August 2021 25 August 2021 4 March 2021 4 March 2021 1 April 2021 1 April 2021 3 May 2021 3 May 2021 13 May 2021 9 June 2021 9 June 2021 9 June 2021 23 June 2021 7 July 2021 7 July 2021 26 August 2021 27 August 2021 27 August 2021 17 June 2022 10 August 2021 10 August 2021 10 August 2021 27 May 2021 18 October 2021 18 October 2021 18 October 2021 18 November 2021 18 November 2021 12 May 2021 27 May 2021 15 June 2021 23 June 2021 Answers 29 April 2021 27 May 2021 6 December 2021 Results Approval, Approval, Approval, Approval, Approval, Approval Other: ML20258A284, ML20269A465, ML20276A192, ML20303A199, ML21036A060, ML21067A504, ML21067A507, ML21084A182, ML21091A004, ML21097A027, ML21145A217, ML21217A187, ML21239A064, ML21239A066, ML21239A068, ML21256A067, ML21256A069, ML21312A002, ML21312A003, ML21312A007, PMNS20211071, Discussion Between NRC and Dominion Regarding the North Anna Subsequent License Renewal - Safety Issue - Cyclic Fatigue, PMNS20211128, Discussion Between NRC and Dominion Regarding the North Anna Subsequent License Renewal - an Inconsistency in Documentation Regarding Reactor Coolant Pump Code Case N 481, TLAA 4.7.6
MONTHYEAR2021-04-29 [Table View]

ML21312A007

Text

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