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Category:Letter
MONTHYEARIR 05000395/20240022024-08-12012 August 2024 Integrated Inspection Report 05000395/2024002 ML24180A0062024-08-0505 August 2024 Issuance of Amendment No. 227 to Modify Technical Specification 3.8.3.1 to Increase Completion Time for 120-Volt A.C. Vital Busses ML24218A3002024-08-0101 August 2024 Environmental Review Response to NRC Requests for Additional Information and Response to NRC Requests for Confirmation of Information Set 1 ML24158A3882024-07-31031 July 2024 Issuance of Amendment No. 226 to Change Emergency Plan Staff Augmentation Times and Relocate Emergency Operations Facility ML24162A3292024-07-0505 July 2024 Letter to E Carr - V.C. Summer Unit 1 - Summary of the May 2024 Audit Regarding the Environmental Review of the Subsequent License Renewal Application IR 05000395/20240112024-06-26026 June 2024 – Comprehensive Engineering Team Inspection Report 05000395/2024011 ML24178A2422024-06-25025 June 2024 2023 Annual Report of Emergency Core Cooling System (ECCS) Model, Changes Pursuant to the Requirements of 10 CFR 50.46 ML24177A1382024-06-25025 June 2024 Aging Management Audit Report- VC Summer, Unit 1 - Subsequent License Renewal Application ML24178A1192024-06-25025 June 2024 Update to License Amendment Request- Inverter Allowed Outage Time (AOT) Extension ML24177A2792024-06-20020 June 2024 Preparation and Scheduling of Operator Licensing Examinations ML24171A0152024-06-17017 June 2024 Update to Subsequent License Renewal Application (SLRA) Response to NRC Request for Additional Information Set 2 Safety Review ML24157A3352024-06-0606 June 2024 – Notification of an NRC Cybersecurity Baseline Inspection (NRC Inspection Report 05000395-2024404 and Request for Information ML24155A2042024-05-31031 May 2024 Proposed Alternative Request RR-24-123, Containment Unbonded Post-Tensioning System Inservice Inspection Requirements ML24155A1462024-05-30030 May 2024 Update to Subsequent License Renewal Application (SLRA) -Response to NRC Request for Additional Information Set 1 Response to NRC Request for Confirmation of Information Set 1 and Supplement 3 ML24143A1792024-05-22022 May 2024 Special Report 2024-001-01 for Virgil C. Summer Nuclear Station (Vcsns), Unit 1, Waste Gas System Inoperability ML24141A2822024-05-20020 May 2024 (Vcsns), Unit 1 - License Amendment Request - Emergency Response Organization (ERO) Augmentation Time Change, Emergency Operations Facility Relocation and Other Emergency Plan Changes IR 05000395/20240012024-05-10010 May 2024 Integrated Inspection Report 05000395/2024001 ML24129A2002024-05-0606 May 2024 Update to Subsequent License Renewal Application, Supplement 2 IR 05000395/20240402024-05-0101 May 2024 95001 Supplemental Inspection Report 05000395/2024040 and Follow-Up Assessment Letter ML24121A1002024-04-29029 April 2024 Response to Request for Additional Information Regarding Alternative Request RR-5-V2 ML24120A2072024-04-29029 April 2024 Submittal of Annual Radiological Environmental Operating Report ML24116A2052024-04-23023 April 2024 Annual Radioactive Effluent Release Report ML24109A1792024-04-19019 April 2024 Aging Management Audit Plan Regarding the Subsequent License Renewal Application Review ML24108A0392024-04-18018 April 2024 Letter to E Carr-V.C. Summer Unit 1- Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application ML24108A0672024-04-17017 April 2024 Submittal of Summary for Condition of the Service Water Intake Structure Provided in Accordance with License Condition 2.C.5.d ML24038A0322024-02-0707 February 2024 (Vcsns), Unit 1, 10 CFR 21 Report - Emergency Diesel Generator Flash Contactor Relay IR 05000395/20230042024-01-31031 January 2024 Integrated Inspection Report 05000395/2023004 ML24022A1202024-01-22022 January 2024 Notification of Target Set Inspection and Request for Information (NRC Inspection Report 05000395/2024403) ML24022A1582024-01-22022 January 2024 (Vcsns), Unit 1 - Reply to a Notice of Violation: EA-23-093 ML24018A0112024-01-18018 January 2024 CFR 21 Report Emergency Diesel Generator Fuel Oil Piping IR 05000395/20230912023-12-21021 December 2023 Final Significance Determination of a White Finding and Notice of Violation and Assessment Followup Letternrc Inspection Report 05000395/2023091 ML23361A1042023-12-21021 December 2023 Inservice Testing Program for Pumps and Valves Fifth Interval Update and Associated Relief and Alternative Requests ML23354A1802023-12-20020 December 2023 301 Examination Report with Cover Letter ML23347A0492023-12-12012 December 2023 Technical Specification Bases Changes Updated Through November 2023 ML23334A2372023-11-30030 November 2023 (Vvsns), Unit 1 - Annual Commitment Change Summary Report ML23334A2462023-11-30030 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23332A1942023-11-28028 November 2023 (Vcsns), Unit 1, Correction of Typographical Error in License Amendment Request - Inverter Allowed Outage Time (AOT) Extension ML23317A2242023-11-0909 November 2023 (Vcsns), Unit 1 - License Amendment Request - Inverter Allowed Outage Time (AOT) Extension ML23289A1152023-11-0303 November 2023 Ltr to R. Nelson - Request for Scoping Comments Concerning the Environmental Review of the V.C. Summer SLRA ML23289A1162023-11-0303 November 2023 Ltr to W. Emerson - Request for Scoping Comments Concerning the Environmental Review of the V.C. Summer SLRA ML23289A1172023-11-0303 November 2023 Tribal Request for Scoping Comments Concerning the Environmental Review of the V.C. Summer SLRA IR 05000395/20230032023-11-0101 November 2023 Integrated Inspection Report 05000395/2023003 IR 05000395/20234032023-11-0101 November 2023 Material Control and Accounting Program Inspection Report 05000395/2023403 Cover ML23284A1792023-10-16016 October 2023 Subsequent License Renewal Application Online Reference Portal ML23275A0142023-10-11011 October 2023 SLRA - Acceptance and Opportunity for Hearing - Letter ML23284A1662023-10-10010 October 2023 (Vcsns), Unit 1 - Request for Regulatory Conference; (EA-23-093) IR 05000395/20230902023-10-0404 October 2023 NRC Inspection Report 05000395/2023090 and Preliminary Yellow Finding and Apparent Violation IR 05000395/20230112023-09-27027 September 2023 Focused Engineering Inspection Report 05000395/2023011 ML23250A3112023-09-20020 September 2023 Request to Revise Reactor Vessel Material Surveillance Capsule Withdrawal Schedules ML23244A2352023-09-18018 September 2023 Request to Use a Subsequent Edition of the ASME Code, Section XI 2024-08-05
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML24218A3002024-08-0101 August 2024 Environmental Review Response to NRC Requests for Additional Information and Response to NRC Requests for Confirmation of Information Set 1 ML24171A0152024-06-17017 June 2024 Update to Subsequent License Renewal Application (SLRA) Response to NRC Request for Additional Information Set 2 Safety Review ML24155A1462024-05-30030 May 2024 Update to Subsequent License Renewal Application (SLRA) -Response to NRC Request for Additional Information Set 1 Response to NRC Request for Confirmation of Information Set 1 and Supplement 3 ML24141A2822024-05-20020 May 2024 (Vcsns), Unit 1 - License Amendment Request - Emergency Response Organization (ERO) Augmentation Time Change, Emergency Operations Facility Relocation and Other Emergency Plan Changes ML24121A1002024-04-29029 April 2024 Response to Request for Additional Information Regarding Alternative Request RR-5-V2 ML22353A5462022-12-19019 December 2022 (Vcsns), Unit 1 - Alternative Request to Defer ASME Code Section XI Inservice Inspection Examinations for Pressurizer and Steam Generator Pressure-Retaining Welds and Full Penetration Welded Nozzles Response to Request ML22300A2202022-10-27027 October 2022 (VCSNS) Unit 1, Alternative Request Rr-4-26 Application for Alternative Request - Extension of Steam Generator Primary Inlet Nozzle Dissimilar Metal Weld Inspection Interval (Volumetric Examination) RAI ML22020A2262022-01-20020 January 2022 Response to Request for Additional Information to License Amendment Request LAR-20-203 Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency ML21180A4052021-06-29029 June 2021 (Vcsns), Unit 1 - Supplement to Request for Additional Information Regarding RF-25 Stem Generator Tube Inspection Report ML21168A2612021-06-17017 June 2021 (Vcsns), Unit 1 - NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-water Reactors - Final Supplemental Response ML21154A1802021-06-0303 June 2021 Response to NRC Request for Additional Information Regarding RGF-25 Steam Generator Tube Inspection Report ML21007A3232021-01-0707 January 2021 License Amendment Request LAR-20-142 Request for Technical Specification Change Technical Specification 3.6.4, Containment Isolation Valves Response to Request for Additional Information (RAI) ML21007A3402021-01-0707 January 2021 (Vcsns), Unit 1 - License Amendment Request LAR-20-176 Update of Analytical Method to the Core Operating Limits Report with the Full Spectrum Loss of Coolant Accident Approach - Response to Request for Additional Info ML20349A3262020-12-14014 December 2020 (Vcsns), Unit 1 - Response to NRC Request for Additional Information Regarding RF-24 Steam Generator Tube Inspection Report ML19282E2612019-10-0909 October 2019 Response to Follow-Up Question to PRA RAI 03, License Amendment Request - LAR-16-01490 NFPA 805 Program Revisions ML19224B1152019-08-12012 August 2019 Response to NRC Follow-Up Question PRA RAI 03, License Amendment Request - LAR-16-01490 NFPA 805 Program Revisions ML19119A3652019-04-29029 April 2019 (Vcsns), Unit 1 - License Amendment Request - LAR-16-01490, NFPA 805 Program Revisions: Response to Request for Additional Information ML19071A3572019-03-11011 March 2019 Request for License Amendment to Virgil C. Summer Nuclear Station Technical Specification 3.8.2., D.C. Sources - Operating, Surveillance Requirements 4.8.2.1.b.2 and 4.8.2.1.c.3 - Request for Additional Information RC-18-0116, (Vcsns), Unit 1 - Request for a One-Time Extension to the Surveillance Frequency 4.4.4.6 of the Core Exit Temperature Instrumentation - Response to Request for Additional Information2018-09-11011 September 2018 (Vcsns), Unit 1 - Request for a One-Time Extension to the Surveillance Frequency 4.4.4.6 of the Core Exit Temperature Instrumentation - Response to Request for Additional Information RC-18-0100, (Vcsns), Unit 1 - Technical Specification Change Request for the Revision of the Surveillance Frequency of the Turbine Trip Functional Unit: Response to Request for Additional Information2018-08-22022 August 2018 (Vcsns), Unit 1 - Technical Specification Change Request for the Revision of the Surveillance Frequency of the Turbine Trip Functional Unit: Response to Request for Additional Information RC-18-0090, (Vcsns), Unit 1 - Relief Request RR-4-16, Request for Alternative to Implement Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Response to Request...2018-07-12012 July 2018 (Vcsns), Unit 1 - Relief Request RR-4-16, Request for Alternative to Implement Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Response to Request... RC-18-0084, Virgil C Summer Nuclear Station (Vcsns), Unit 1 - Relief Request RR-4-15, Request for Alternative to Implement Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Laws in Moderate Energy Class 2 or 3 Piping Response to Requ2018-07-0303 July 2018 Virgil C Summer Nuclear Station (Vcsns), Unit 1 - Relief Request RR-4-15, Request for Alternative to Implement Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Laws in Moderate Energy Class 2 or 3 Piping Response to Reques RC-18-0046, License Amendment Request LAR-14-01541 Integrated Leak Rate Test Peak Calculated Containment Internal Pressure Change Request for Additional Information2018-04-19019 April 2018 License Amendment Request LAR-14-01541 Integrated Leak Rate Test Peak Calculated Containment Internal Pressure Change Request for Additional Information RC-18-0036, (Vcsns), Unit 1 - Relief Request RR-4-13, Use of a Risk-Informed Process as an Alternative for the Selection of Class 1 and Class 2 Piping Welds - Response to Request for Additional Information2018-04-0202 April 2018 (Vcsns), Unit 1 - Relief Request RR-4-13, Use of a Risk-Informed Process as an Alternative for the Selection of Class 1 and Class 2 Piping Welds - Response to Request for Additional Information RC-17-0134, Response to Request for Supplemental Information, License Amendment Request - LAR-15-01424; Implementation of WCAP-15376-P-A, Revision 12017-09-27027 September 2017 Response to Request for Supplemental Information, License Amendment Request - LAR-15-01424; Implementation of WCAP-15376-P-A, Revision 1 RC-17-0093, License Amendment Request - LAR-15-01424 Implementation of WCAP-15376-P-A, Revision 1 - Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, Response To.2017-07-0606 July 2017 License Amendment Request - LAR-15-01424 Implementation of WCAP-15376-P-A, Revision 1 - Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, Response To. RC-17-0088, Implementation of WCAP-15376-P-A, Revision 1 - Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times - Response to Request for Additional Information2017-06-22022 June 2017 Implementation of WCAP-15376-P-A, Revision 1 - Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times - Response to Request for Additional Information RC-17-0032, Spent Fuel Evaluation Supplemental Report, Response to NRC for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident2017-03-30030 March 2017 Spent Fuel Evaluation Supplemental Report, Response to NRC for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident ML17087A1512017-03-28028 March 2017 Response to Request for Additional Information on VC Summer Sfpli RC-17-0019, Response to Request for Additional Information Regarding License Amendment Request LAR-15-01424, Implementation of WCAP-15376-P-A, Revision 12017-02-0606 February 2017 Response to Request for Additional Information Regarding License Amendment Request LAR-15-01424, Implementation of WCAP-15376-P-A, Revision 1 RC-16-0147, VC Summer Nuclear Station, Unit 1, Response to Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools Pursuant to Title 10 9f the Code of Federal Regulations 05.54(f)2016-11-0303 November 2016 VC Summer Nuclear Station, Unit 1, Response to Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools Pursuant to Title 10 9f the Code of Federal Regulations 05.54(f) ML16235A2422016-08-18018 August 2016 Response to Request for Information for Triennial Fire Protection Baseline Inspection RC-16-0091, Response to Request for Additional Information on Relief Request RR-III-12 Proposed Alternative Inspection Requirements for Piping Welds2016-06-0202 June 2016 Response to Request for Additional Information on Relief Request RR-III-12 Proposed Alternative Inspection Requirements for Piping Welds RC-16-0077, Relief Request RR-III-12, Proposed Alternative Inspection Requirements for Piping Welds - Response to Request for Additional Information2016-05-0606 May 2016 Relief Request RR-III-12, Proposed Alternative Inspection Requirements for Piping Welds - Response to Request for Additional Information RC-16-0046, Response to Request for Additional Information on Relief Request RR-III-2, Proposed Alternative Inspection Requirements for Piping Welds2016-03-18018 March 2016 Response to Request for Additional Information on Relief Request RR-III-2, Proposed Alternative Inspection Requirements for Piping Welds RC-16-0036, License Amendment Request - LAR-15-01424 - Implementation of WCAP-15376-P-A, Revision 1, Response to Request for Supplemental Information2016-03-0707 March 2016 License Amendment Request - LAR-15-01424 - Implementation of WCAP-15376-P-A, Revision 1, Response to Request for Supplemental Information RC-16-0031, License Amendment Request - LAR-12-04269, License Basis Changes in Steam Generator Tube Rupture Analysis Supplement Response2016-03-0404 March 2016 License Amendment Request - LAR-12-04269, License Basis Changes in Steam Generator Tube Rupture Analysis Supplement Response RC-16-0039, Exigent License Amendment Request - LAR (16-00848), Technical Specification Change Request for Emergency Feedwater System Limiting Condition for Operation 3.7.1.2 Action B - Response to Request for Additional..2016-03-0303 March 2016 Exigent License Amendment Request - LAR (16-00848), Technical Specification Change Request for Emergency Feedwater System Limiting Condition for Operation 3.7.1.2 Action B - Response to Request for Additional.. RC-16-0001, V.C. Summer, Report of Full Compliance with March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051) and Responses to Requests for Additional Information2016-01-22022 January 2016 V.C. Summer, Report of Full Compliance with March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051) and Responses to Requests for Additional Information RC-16-0006, Response to Request for Additional Information to License Amendment Request - LAR-12-04269, License Basis Changes in Steam Generator Tube Rupture Analysis2016-01-14014 January 2016 Response to Request for Additional Information to License Amendment Request - LAR-12-04269, License Basis Changes in Steam Generator Tube Rupture Analysis RC-15-0186, Response to Request for Information (NRC Inspection Report No. 05000395/2015404)2015-11-11011 November 2015 Response to Request for Information (NRC Inspection Report No. 05000395/2015404) IR 05000395/20154042015-11-11011 November 2015 V.C. Summer, Unit 1 - Response to Request for Information (NRC Inspection Report No. 05000395/2015404) RC-15-0160, Response to Request for Information (NRC Inspection Report No. 05000395/2015404)2015-09-25025 September 2015 Response to Request for Information (NRC Inspection Report No. 05000395/2015404) ML15310A0762015-09-21021 September 2015 Response to Request for Information to Support the Cyber Security Inspection RC-15-0142, License Amendment Request, LAR 12-04269, License Basis Changes in Steam Generator Tube Rupture Analysis, Response to Request for Additional Information2015-09-10010 September 2015 License Amendment Request, LAR 12-04269, License Basis Changes in Steam Generator Tube Rupture Analysis, Response to Request for Additional Information RC-15-0116, Response to NRC Request for Information Baseline Radiation Safety Inspection2015-07-13013 July 2015 Response to NRC Request for Information Baseline Radiation Safety Inspection 2024-08-01
[Table view] |
Text
Serial No.: 24-222 Docket No.: 50-395
Enclosure 1
RESPONSE TO VCS SLRA REQUEST FOR ADDITIONAL INFORMATION SET 2 SAFETY REVIEW
Dominion Energy South Carolina, Inc.
(Dominion Energy South Carolina, or DESC)
Virgil C. Summer Nuclear Station Unit 1 Serial No.: 24-222 Docket No.: 50-395 Enclosure 1, Page 2 of 6
By letter dated August 17, 2023 [Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML23233A179], Dominion Energy South Carolina, Inc.
(Dominion, Dominion Energy South Carolina, or DESC) submitted an application for the subsequent license renewal of Renewed Facility Operating License No. NPF-12 for Virgil C. Summer Nuclear Station (VCSNS) Unit 1.
The NRC staff has identified areas where additional information is needed to complete their review. In an email from Marieliz Johnson (NRC) to Eric S. Carr (DESC), dated May 6, 2024 (ADAMS Accession No. ML24127A110), the NRC staff transmitted Set 1 of their requests for additional information (RAIs) to support completion of the Safety Review. DESC responded to RAI Set 1 by letter dated May 30, 2024 (ADAMS Package No. ML24155A146).
In an email from Marieliz Johnson (NRC) to Eric S. Carr (DESC), dated June 3, 2024 (ADAMS Accession No. ML24156A001), the NRC staff transmitted Set 2 of their RAIs for Safety Review. DESC agreed to respond within 30 days of receipt of RAI Set 2.
The NRCs RAIs and DESCs RAI responses for Set 2 (Safety Review) are provided in this enclosure.
RAI 3.3.2.2.7-1 Regulatory Basis
10 CFR 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a),
the staff requires additional information in regard to the matters described below.
=
Background===
NUREG-2192 provides a standard review plan for subsequent license renewal applications (SRP-SLR). Section 3.3.2.2 of the SRP-SLR provides aging management review results for which further evaluation is recommended. SRP-SLR, Section 3.3.2.2.7 provides recommendations for the further evaluation of recurring internal corrosion. Included in these recommendations are that the applicant state:
(a) why the programs examination methods will be sufficient to detect the recurring aging effect before affecting the ability of a component to perform its intended function,
Serial No.: 24-222 Docket No.: 50-395 Enclosure 1, Page 3 of 6
(b) the basis for the adequacy of augmented or lack of augmented inspections, (c) what parameters will be trended as well as the decision points where increased inspections would be implemented (e.g., the extent of degradation at individual corrosion sites, the rate of degradation change),
(d) how inspections of components that are not easily accessed (i.e., buried, underground) will be conducted, and
(e) how leaks in any involved buried or underground components will be identified.
Issue
- 1. SLRA section 3.3.2.2.7, Loss of Material Due to Recurring Internal Corrosion, subsection B, Fire Water System (B2.1.16) program, states in part that the applicant will meet SRP-SLR criterion (a) by using the Low Frequency Electromagnetic Technique (LFET) or similar technique for screening piping during each refueling cycle, and that thinned areas found during this scan are followed up with wall thickness examinations. SLRA section 3.3.2.2.7, subsection B, does not discuss LFET in its writeup on inspection of components that are not easily accessed (SRP-SLR criterion (d)). The context of SLRA section 3.3.2.2.7 suggests that LFET will not be used for inspection of components that are not easily accessed.
- 2. SLRA section 3.3.2.2.7, subsection B, describes in its discussion of SRP-SLR criterion (d) a condition assessment requiring the sectioning of pipe that was performed in 2022.
The SLRA refers to the 2022 condition assessment of the pipe sections as inspections and then follows with a discussion of future inspections. It is not clear to the NRC staff if this discussion indicates that the applicant plans to inspect components not easily accessed during the period of extended operation by performing similar pipe sectioning.
Request
- 1. Clarify whether or not the LFET or similar technique for screening piping, as discussed in SLRA section 3.3.2.2.7, subsection B, will be used in areas that are not easily accessed (i.e. buried or underground).
- 2. Clarify the discussion of SRP-SLR criterion (d) in SLRA section 3.3.2.2.7, subsection B.
Does the applicant intend to inspect components not easily accessed during the period of extended operation by performing similar pipe sectioning?
DESC Response to RAI 3.3.2.2.7-1
- 1. Recurring Internal Corrosion (RIC) has been identified in unlined/uncoated steel fire service piping within the scope of the Fire Water System (B2.1.16) program.
Accordingly, LFET or a similar technique will be used to screen fire service piping subject to RIC. The fire service piping that is not easily accessed (i.e., buried piping)
Serial No.: 24-222 Docket No.: 50-395 Enclosure 1, Page 4 of 6
is cement-lined and is not subject to RIC. Therefore, screening of the cement-lined fire service piping for wall thinning due to RIC will not be performed.
- 2. The fire service piping that is not easily accessed (i.e., buried piping) is cement-lined and is not subject to RIC. The inspections performed in July 2022 are identified in B2.1.28, Buried and Underground Piping and Tanks (Operating Experience #7) and B2.1.21, Selective Leaching (Operating Experience #3). These inspections were primarily focused on identifying the extent of exterior-initiated selective leaching of the buried piping. The pipe was sectioned at locations with the deepest exterior loss of material to get a more accurate measurement of corrosion depth. During the inspection, it was noted that the inside of the ductile iron pipe was in excellent condition and the mortar lining on the inside surface was in good to excellent condition.
Aging Management Program B2.1.29, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks permits opportunistic inspections of the lining of buried internally coated/lined fire water system piping, in lieu of periodic inspections. Three conditions related to flow testing, monitoring system pressure, and operating experience must be fulfilled to use the opportunistic inspection provision. These conditions are being met for the buried fire service piping at VCSNS. Opportunistic inspections of internal coating/lining do not require sectioning of pipe.
RAI B2.1.15-1 Regulatory Basis
Section 54.21(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the U.S. Nuclear Regulatory Commission (NRC) staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a),
the staff requires additional information in regard to the matters described in the requests for information.
=
Background===
The Monitoring and Trending program element in Aging Management Program (AMP)
XI.M26, Fire Protection, in Volume 2 of NUREG-2191, Generic Aging Lessons Learned Serial No.: 24-222 Docket No.: 50-395 Enclosure 1, Page 5 of 6
for Subsequent License Renewal (GALL-SLR) Report (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17187A204), states the following:
- The results of inspections of the aging effects of cracking and loss of material on fire barrier penetration seals, fire barriers, fire damper assemblies, and fire doors are trended to provide for timely detection of aging effects so that the appropriate corrective actions can be taken. [NOTE: Draft Revision 1 of the GALL-SLR, Volume 2, proposes to clarify the Monitoring and Trending program element in AMP XI.M26 to indicate inspection results of all aging effects be trended (ML23180A188).]
- The performance of the halon/CO2 fire suppression system is monitored during the periodic test to detect any degradation in the system. These periodic tests provide data necessary for trending.
Issue
Subsequent License Renewal Application (SLRA) Supplement 2 dated May 6, 2024 (ML24129A200), revised and renumbered the enhancement to the Monitoring and Trending program element (renumbered from enhancement 2 to enhancement 3). The revised enhancement in SLRA Table A4.0-1 and SLRA Section B2.1.15 states, in part, Procedure(s) will be revised to specify that inspection results of materials susceptible to delamination, change in material properties, separation, increased hardness, shrinkage, or loss of strength will be trended. However, it is unclear to the NRC staff why the revised enhancement does not include loss of material and cracking, which are applicable aging effects for fire barriers as indicated in the SLRA (e.g., SLRA Table 3.5.2-14).
SLRA Supplement 2 dated May 6, 2024 (ML24129A200), added a new enhancement to the Monitoring and Trending Program element (new enhancement 4). The new enhancement in SLRA Table A4.0-1 and SLRA Section B2.1.15 states, in part, Procedure(s) will be revised to specify that inspections will be performed to identify cracking and loss of material for CO2 fire protection system components, and that those results are trended and appropriate corrective actions identified, if necessary. The added enhancement appears to address trending of the visual inspection results of the CO2 fire protection system but does not address trending the results of the periodic tests of the CO2 fire protection system.
Therefore, it is unclear whether the results of the periodic tests of the CO2 fire protection system will be trended during the subsequent period of extended operation.
Request:
- 1. Please discuss why revised and renumbered enhancement 3 does not include loss of material and cracking since they are applicable aging effects for fire barriers as indicated in the SLRA.
- 2. Consistent with the Monitoring and Trending program element in GALL-SLR Report AMP XI.M26, please discuss whether trending of the CO2 fire suppression system periodic test results will be performed during the subsequent period of extended operation, including any changes needed to new enhancement 4.
Serial No.: 24-222 Docket No.: 50-395 Enclosure 1, Page 6 of 6
DESC Response to RAI B2.1.15-1
- 1. Enhancement 3 of the Fire Protection Program has been revised to include the aging effects of loss of material and cracking. The updated enhancement is provided in the Enclosure 2 markups.
- 2. Enhancement 4 of the Fire Protection Program has been revised to state that the results of the periodic tests of the CO2 fire protection system will be trended during the subsequent period of extended operation The updated enhancement is provided in the Enclosure 2 markups.
Serial No.: 24-222 Docket No.: 50-395
Enclosure 2
SLRA MARK-UPS REQUEST FOR ADDITIONAL INFORMATION SET 2 SAFETY REVIEW
Dominion Energy South Carolina, Inc.
(Dominion Energy South Carolina, or DESC)
Virgil C. Summer Nuclear Station Unit 1
Enclosure 2 Serial No.: 24-222 Page 3 of 4 Virgil C. Summer Nuclear Station Application for Subseq uent License Renewal RAI Set 2 Appendix B - Aging Management Programs
The Fire Protection program is a risk-informed, performance-based program built upon National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. Adoption of NFPA 805 in accordance with Title 10 of the Code of Federal Regulations (1 0 CFR) 50.48(c) serves as the method of satisfying 10 CFR 50.48(a) and General Design Criterion 3.
NUREG-2191 Consistency The Fire Protection program is an existing program that, following enhancement, will be consistent with NUREG-2191,Section XI.M26, Fire Protection, as modified by SLR-ISG-2021-02-MECHANICAL, "Updated Aging Management Criteria for Mechanical Portions of the Subsequent License Renewal Guidance."
Exception Summary None Enhancements Prior to the subsequent period of extended operation, the following enhancements will be implemented in the following program elements:
Scope of Program (Element 1), Parameters Monitored / Inspected (Element 3); Detection of Aging Effects (Element 4); and Acceptance Criteria (Element 6)
- 1. Procedure(s) will be revised to provide guidance for detection of loss of material, cracking, holes, and gaps during the visual inspections of fire dampers to ensure that any deficiencies are noted on a condition report, and to determine the acceptability of the findings. (Revised -
Supplement 2)
- 2. Procedure(s) will be revised to require that inspections of fire barrier elastomeric penetration seals and seismic gap filler identify shrinkage, loss of strength, and hardening, or any other sign of degradation. (Added - Supplement 2)
Monitoring and Trending (Element 5)
- 3. Procedure(s) will be revised to specify that inspection results of materials susceptible to loss of material, cracking, delamination, change in material properties , separation, increased hardness, shrinkage, or loss of strength will be trended. Where practical, identified degradation will be projected until the next scheduled inspection. Resu lts will be evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate of degradation. (Renumbered and Revised - Supplement 2 ,
Revised - RAI Set 2)
Page B-86 Enclosure 2 Serial No.: 24-222 Page 4 of 4 Virgil C. Summer Nuclear Station Application for Subseq uent License Renewal RAI Set 2 Appendix B - Aging Management Programs
- 4. Procedure(s) will be revised to specify that inspections will be performed to identify cracking and loss of material for CO 2 fire protection system components, and that those results are trended and appropriate corre ctive actions identifie d, if necessary. Wher e practical, identified degradation will be projected until the next scheduled inspection. Re sults will be evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate of degradation. Trending of the results of the CO2 fire suppression system periodic tests will also be performed. (Added - Supplement 2, Revised - RAI Set 2)
Corrective Actions (Element 7)
- 5. Procedure(s) will be revised to specify that for inspection results that will fail to meet acceptance criteria prior to the next sched uled inspection, inspection frequencies will be adjusted as determined by the Corrective Action Program. (Renumbered and Revised -
Supplement 2)
Operating Experience Summary The following examples of operating experience provide objective evidence that the Fire Protection program has been, and will be, effective in managing the aging effects for SSCs within the scope of the program so that the intended functions will be maintained consistent with the current licensing basis during the subsequent period of extended operation.
- 1. In July 2014, a 1-inch diameter hole was identified on a gypsum fire barrier wall in the switchgear room. The hole penetrated the gypsum (fire barrier) but not the corrugated steel on the opposite side (pressure boun dary). The pressure boundary was intact, but the fire barrier was degraded. The hole in the gypsum board was patched with joint compound to correct the condition and restore the function of the gypsum wall as a fire barrier.
- 2. In February 2015, during a plant walkdown, a fire barrier penetration seal was found to contain a void. The penetration was supposed to contain 10 inches of foam seal material. The degradation was 3-2/3 inches deep within th e 10-inch foam, and was approximately 6 inches high. It appeared to be due to shrinkage rather than any external damage. The void in the penetration seal was filled with the required amount of additional foam sealant to correct the condition, and to restore the penetration seal as a fire barrier.
- 3. In March 2016, during scheduled inspections of fire barriers in the Control Building, it was identified that the Kaowool fire barrier for one of the penetrations was degraded due to a gap between the Kaowool triple wrap and the adjace nt drywall. The gap was closed using RTV fire-resistant foam to reconnect the Kaowool triple wrap to the drywall, thus correcting the condition and restoring the fire barrier function.
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