ML24078A264
| ML24078A264 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/21/2024 |
| From: | Klos L Plant Licensing Branch II |
| To: | Carr E Dominion Energy Virginia |
| Klos, J | |
| References | |
| EPID L-2023-LLA-0115 | |
| Download: ML24078A264 (1) | |
Text
March 21, 2024 Eric S. Carr President - Nuclear Operations and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
SURRY POWER STATION, UNIT NOS. 1 AND 2 - REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUEST FOR PROPOSED RECLASSIFICATION OF LOW HEAD SAFETY INJECTION FLOW INSTRUMENTATION RELATED TO REGULATORY GUIDE 1.97 (EPID L-2023-LLA-0115)
Dear Eric S. Carr:
By letters dated August 10, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23226A186, Virginia Electric and Power Company (Dominion Energy Virginia) submitted a license amendment request (LAR) to amend the license and technical specifications (TSs) for Surry Power Station (Surry), Units 1 and 2, Renewed Facility Operating License No. DPR-32 and DPR-37, respectively. The proposed amendments would revise the Surry TS to reclassify Low Head Safety Injection (LHSI) flow instrumentation and accident monitoring instrumentation related to Regulatory Guide (RG) 1.97, Revision 3 (ML003740282), Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants variable from a Type D category variable to a Type 1 variable.
The U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine the Dominion Energy Virginias non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
The NRC staff will conduct the audit in person and virtually via Teams using a licensee-established electronic portal available to NRC staff from approximately during a two-week period between April 3-24, 2024 with formal audit meetings to be scheduled during this period, as needed.
If you have any questions, please contact me by telephone at 301-415-5136 or by email to John.Klos@nrc.gov.
Sincerely,
/RA/
L. John Klos, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281
Enclosure:
Audit Plan cc: Listserv
REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST FOR RECLASSIFICATION OF LOW HEAD SAFETY INJECTION FLOW INSTRUMENTATION RELATED TO REGULATORY GUIDE 1.97 DOMINION ENERGY VIRGINIA SURRY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-280 AND 50-281
1.0 BACKGROUND
By letters dated August 10, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23226A186, Virginia Electric and Power Company (Dominion Energy Virginia) submitted a license amendment request (LAR) to amend the license and technical specifications (TSs)for Surry Power Station (Surry), Units 1 and 2, Renewed Facility Operating License No. DPR-32 and DPR-37, respectively. The proposed amendments would revise the Surry TS to reclassify Low Head Safety Injection (LHSI) flow instrumentation and accident monitoring instrumentation related to Regulatory Guide (RG) 1.97, Revision 3 (ML003740282), Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants, variable from a Type D category variable to a Type 1 variable.
The staff from the Nuclear Regulatory Commissions(NRCs) Office of Nuclear Reactor Regulation(NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures (ML19248C539).
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license, or regulation-related activity that includes the examination and evaluation of Dominion Energy Virginias non-docketed information that provides the technical basis for the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR LIC-111, Regulatory Audits, with exceptions noted within this audit plan (ML19226A274)
The NRC staff will perform the audit to support its evaluation of whether the licensees requests can be approved per 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit.
3.0 SCOPE The audit team will view the documentation and calculations that provide the technical support for the LARs. The scope of the NRC staffs audit will focus on the following subjects:
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LARs and confirm the staffs understanding of the LARs.
Gain a better understanding of plant design features and implications for the LAR request.
Identify any information needed to enable the staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify the NRC-approved methodologies used for the analyses of loss-of-coolant accident (LOCA), material & equipment (M&E) release in containment, LOCA containment response (i.e., transient containment pressure, vapor temperature, and sump water temperature).
Identify the key inputs and assumptions used in the analyses, confirming the inputs are sufficient for determining the limiting transient net positive suction head (NPSH), and understanding the justification for any conservatisms applied.
Determine the output results of the analyses and to specifically evaluate containment pressure, vapor temperature, and sump water temperature responses, including their peak values calculated.
Identify the available NPSH and required NPSH values with single Low Head Safety Injection (LHSI) pump operating at high (unthrottled) flow and at the proposed design (throttled) flow.
Identify the values of containment accident pressure (CAP), if used, in determining the available NPSH at various flows conditions to understand indicating parameters that may be below, or above, the vapor pressure at the corresponding sump water temperature.
Provide the impact of the lesser flow, due to the proposed lowered flow from the single LHSI pump, on the long-term decay heat removal and the containment cooling temperature and pressure profile.
Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff will request information throughout the audit period. The NRC staff will identify the information to be audited (e.g., methodology, process information, and calculations) and the subjects of requested meetings.
The NRC staff requests the licensee to have the information identified above available and accessible for the NRC staffs review via a web-based electronic portal within two weeks, or earlier, of the date of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within approximately one week of the date of the NRCs notification to the licensee of the new requests. The NRC staff requests the licensee to notify the review team when the audit item is added to its electronic portal by sending an email to the NRC licensing project manager.
The NRC staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff.
5.0 AUDIT TEAM The following table identifies the NRC audit team members, including contractors, and their respective focus areas:
Name E-mail Review Area (Organization)
John Klos John.Klos@nrc.gov Plant Licensing Branch LPL II-1 (LPL2-1)
Ahsan Sallman Ahsan.Sallman@nrc.gov Nuclear Systems Performance Branch (SNSB) 6.0 LOGISTICS The audit will be conducted using a secure, online electronic portal, established by the licensee to present supporting documentation and calculations and by teleconferences with Dominion Energy Virginias subject matter experts, virtually. The audit will begin within two weeks of the date of this audit plan (approximately April 3-24. 2024). The NRC will establish a schedule of audit teleconferences on mutually agreeable dates and times to discuss information needs and questions arising from the NRCs review of the audited items. The NRCs licensing project manager will inform the licensee of audit meeting dates when they are established. Audit meeting agenda and questions will be sent in advance of the audit teleconferences.
7.0 SPECIAL REQUESTS The following conditions associated with the online web-based electronic portal should be maintained while the NRC staff and contractors on the audit team have access to the online portal:
The online electronic portal will be password-protected, and separate passwords will be assigned to each member of the audit team.
The online web-based electronic portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information from the web portal.
Conditions of use of the online electronic portal will be displayed on the login screen and will require acknowledgment by each user.
Dominion Energy Virginia is expected to provide username and password information directly to the NRC staff audit team, listed above. The NRC project manager will provide Dominion Energy Virginia the names and contact information if any NRC staff may need to be added to the audit team. All other communications should be coordinated with the NRC project manager. The NRCs project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the electronic portal.
No data accessed by the audit team members will be retained by the NRC following the conclusion of the audit.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, in accordance with NRR LIC-115 and issue such RAIs separate from audit-related correspondence. The NRC staff will issue an audit summary report within approximately 90 days after the end of the audit and prior to completing its safety evaluation of the LAR.
ML24078A264 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/SNSB/(A)BC NAME JKlos KGoldstein JAmbrosini for PSahd DATE 03/15/2024 03/20/2024 03/20/2024 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley JKlos DATE 03/21/2023 03/21/2023