ML25106A308
| ML25106A308 | |
| Person / Time | |
|---|---|
| Issue date: | 03/06/2025 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-0242 | |
| Download: ML25106A308 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
723rd Meeting Advisory Committee on Reactor Safeguards Location:
teleconference Date:
Thursday, March 6, 2025 Work Order No.:
NRC-0242 Pages 1-100 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 723rd MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 THURSDAY 8
MARCH 6, 2025 9
+ + + + +
10 11 The Advisory Committee met via video 12 teleconference, at 8:30 a.m. EST, Walter L. Kirchner, 13 Chair, presiding.
14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 COMMITTEE MEMBERS:
1 WALTER L. KIRCHNER, Chair 2
GREGORY H. HALNON, Vice Chair 3
DAVID A. PETTI, Member-at-Large 4
RONALD G. BALLINGER 5
VICKI M. BIER 6
VESNA B. DIMITRIJEVIC
- 7 CRAIG D. HARRINGTON 8
ROBERT P. MARTIN 9
SCOTT P. PALMTAG 10 THOMAS E. ROBERTS 11 MATTHEW W. SUNSERI 12 ACRS CONSULTANT:
- 14 15 DESIGNATED FEDERAL OFFICIAL:
16 CHRISTINA ANTONESCU 17 18 19 20 21 22 23 24
- Present via telephone 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 ALSO PRESENT:
1 RICHARD BURTT 2
WILLIAM KEARNEY 3
STEVE DOWNEY 4
PAMELA GREENLAW 5
BETH JENKINS 7
JASON PAIGE 10 MAC REED 11 APRIL RICE 12 JUDD RUTH 13 SHABAZZ RAYMOND 14 CHUCK TOMES 15 JOHN WISE 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 CONTENTS 1
Call to Order and Opening Remarks........
5 2
Walt Kirchner, Chair 3
V.C. Summer Subsequent License Renewal 4
Application Review 8
5 V.C. Summer Nuclear Station Presentation
.... 13 6
Staff Presentation
............... 62 7
Public Comments................. 97 8
Adjourn 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 P-R-O-C-E-E-D-I-N-G-S 1
8:30 a.m.
2 CHAIR KIRCHNER: Good morning. This 3
meeting will now come to order.
4 This is the second day of the 723rd 5
meeting of the Advisory Committee on Reactor 6
Safeguards, ACRS.
7 I'm Walt Kirchner, Chairman of the ACRS.
8 ACRS members in attendance in person are Ron 9
Ballinger, Greg Halnon, Robert Martin, Scott Palmtag, 10 Dave Petti, Thomas Roberts, Craig Harrington, Matt 11 Sunseri, and Vicki Bier. Attending virtually is Vesna 12 Dimitrijevic.
13 And today, I do not think we have any of 14 our consultant joining us. Or, Steve, are you there?
15 MR. SCHULTZ: I'm here.
16 CHAIR KIRCHNER: Okay. Steve Schultz.
17 Thank you.
18 If I've missed anyone, either ACRS members 19 or consultants, please speak up now.
20 (No response.)
21 Kent Howard of the ACRS staff is the 22 Designated Federal Officer for this morning's full 23 Committee meeting.
24 No member conflicts of interest were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 identified for today's meeting.
1 And I note that we have a quorum.
2 The ACRS was established by statute and is 3
governed by the Federal Advisory Committee Act, or 4
FACA. The NRC implements FACA in accordance with our 5
regulations.
6 Per these regulations and the Committee's 7
Bylaws, the ACRS speaks only through its published 8
Letter Reports. All member comments, therefore, 9
should be regarded as only the individual opinion of 10 that member and not a Committee position.
11 All relevant information related to ACRS 12 activities, such as letters, rules for meeting 13 participation, and transcripts, are located on the NRC 14 public website and can be readily found by typing 15 "About Us ACRS" in the search field on the NRC's home 16 page.
17 The ACRS, consistent with the agency's 18 value of public transparency and regulation of nuclear 19 facilities, provides opportunity for public input and 20 comment during our proceedings. We have received no 21 written statements or requests to make an oral 22 statement from the public. However, we have set aside 23 time at the end of the meeting for public comments.
24 Written statements may be forwarded to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 today's Designated Federal Officer. And again, that's 1
2 A transcript of the meeting is being kept 3
and will be posted on our website.
4 When addressing the Committee, the 5
participants should first identify themselves and 6
speak with sufficient clarity and volume, so that they 7
may be readily heard. If you are not speaking -- this 8
is important -- please mute your computer on Teams or, 9
if you are participating by phone, press *6 to mute 10 your phone, and *5 to raise your hand on Teams.
11 The Teams chat feature will not be 12 available for use during the meeting.
13 For everyone in the room, we ask that you 14 please put your electronic devices in silent mode and 15 mute your laptop microphone and speakers.
16 In
- addition, please keep sidebar 17 discussions in the room to a minimum, since the 18 ceiling microphones are live.
19 For presenters -- and this is important --
20 these microphones are unidirectional. You'll need to 21 speak into the front of the microphone to be heard 22 online, especially by our court reporter.
23 Finally, if you have any feedback about 24 today's meeting, we encourage you to fill out the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 public meeting feedback form on the NRC's website.
1 During today's meeting, we will consider 2
the following topic, which is the V.C. Summer 3
subsequent license renewal application.
4 Portions of this meeting may be closed to 5
protect sensitive information, as required by FACA and 6
the Government in Sunshine Act. Attendance during the 7
closed portion of the meeting will be limited to NRC 8
staff and its consultants, Dominion Energy, and those 9
individuals and organizations who have entered into an 10 appropriate confidentiality agreement. We will 11 confirm that only eligible individuals are in that 12 closed portion of the meeting.
13 And with that, unless there are any 14 comments from members, I will now turn the Committee's 15 deliberations over to our License Renewal Subcommittee 16 Chairman, Matt Sunseri.
17 Matt?
18 MEMBER SUNSERI: Thank you, Chairman 19 Kirchner.
20 As you mentioned, during today's meeting 21 the ACRS full Committee will receive a briefing on the 22 technical issues for the Virgil C. Summer Nuclear 23 Station Unit 1 subsequent license renewal application 24 from Dominion Energy, South Carolina, and the NRC 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 staff.
1 We review these subsequent license renewal 2
applications to assure that the aging management 3
programs that the licensee is implementing are 4
well-suited to support the period of license 5
extension.
6 And we contribute by adding our own 7
operational experience on aging management to the 8
process. As you know, aging management is important 9
in our operating experience for input to the review 10 process. And so, this gives us an opportunity to 11 share our experience with the process.
12 For those followers that observe ACRS 13 meetings closely, you will notice that we are doing a 14 different approach to this subsequent license and 15 initial license renewal reviews. Because of the 16 maturity of the industry's experience with aging 17 management programs and the license renewal processes, 18 and the repetitive quality submittals by the 19 applicants, very high quality submittals, this allows 20 us to forego having a
Subcommittee meeting 21 specifically on the topic. What our Subcommittee does 22 is we review the material virtually in preparation for 23 this meeting.
24 So, just assuring, although there wasn't 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 a Subcommittee briefing, but, specifically, the 1
Subcommittee has done a deep-dive review of all the 2
material that was submitted. And it was pretty 3
substantial. For those that don't really know a 4
subsequent license renewal application, I think this 5
one had over 1400 pages or something like that. So, 6
it's a pretty in-depth process.
7 But, for transparency reasons, then we 8
bring forward the briefing into the full Committee 9
meeting. So, the staff and the Applicant will present 10 their cases today. We will deliberate in the light of 11 sunshine, and then, we'll produce a Letter Report with 12 our findings following today's briefing.
13 So, as Walt also mentioned, there is a 14 session reserved for some proprietary information. I 15 don't necessarily anticipate any, unless there's some 16 questions asked, and then, we may have to go into a 17 proprietary session to discuss those. But we'll just 18 see where that goes.
19 Anyway, that's all I have as far as 20 introduction. Any questions for me?
21 (No response.)
22 So, without any further questions, I'll 23 turn it over to Mr. Jason Paige, Acting Director of 24 the Division of Engineering and External Hazards.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 Jason?
1 MR. PAIGE: Thank you, Chairman.
2 Good morning. Jason Paige, Acting Deputy 3
Director of the Division of (audio interference) 4 Licenses in the Office of Nuclear Reactor Regulation.
5 We appreciate the opportunity today to 6
present to the ACRS the results of the staff's review 7
on the application for subsequent license renewal.
8 This application was submitted by Dominion 9
Energy for the V.C. Summer Nuclear Station Unit 1 10 located in Jenkinsville, South Carolina.
11 For background, V.C. Summer Unit 1 12 received approval for its initial license renewal from 13 the Nuclear Regulatory Commission April 24th, 2004.
14 The NRC review at that time was performed using 15 guidance from the initial version of the Generic Aging 16 Lessons Learned Report, or the GALL. The initial GALL 17 Report was issued in 2001.
18 The NRC Guidance for License Renewal has 19 evolved over the years through enhancements and 20 improvements based on lesson learned from the NRC 21 application reviews and from consideration of both 22 domestic international industry operating experience.
23 The initial GALL Report for License 24 Renewal went through two revisions with additional 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 Interim Staff Guidance revised changes following 1
Revision 2. Gall Report Revision 2, along with these 2
ISGs, were used to develop the guidance for subsequent 3
license renewal that's contained in the GALL-SLR 4
Report.
5 In addition to the previous license 6
renewal guidance, the GALL-SLR report includes 7
additional focus on aging management and time-limiting 8
aging analyses for operation in the 60-to-80-year time 9
period.
10 Regarding our review team for the V.C.
11 Summer application, the NRC Project Manager for the 12 V.C. Summer subsequent license renewal application 13 Review is Marieliz Johnson. And she will introduce 14 the staff who will be presenting today and addressing 15 your questions regarding the safety review.
16 Staff's safety review of the V.C. Summer 17 subsequent license renewal application is documented 18 in the Safety Evaluation issued on January 21st, 2025, 19 and was revised on March 4th, 2025, to address an 20 administrative change that more accurately describes 21 the Applicant's implementation of an aging management 22 program. Merieliz will provide additional details on 23 that aging management program.
24 I would like to note that the staff 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 completed its review with no confirmatory items in the 1
Safety Evaluation.
2 And finally, we will address any questions 3
you may have on the staff's presentation. We look 4
forward to a productive discussion today with the 5
ACRS.
6 At this time, I would like to turn the 7
presentation over to Mr. Keith Miller, Subsequent 8
License Renewal Supervisor at Dominion Energy, South 9
Carolina, to introduce his team and commence the 10 presentation.
11 MR. MILLER: Thank you.
12 Good morning, Chair Kirchner and Members 13 of the Committee.
14 My name is Keith Miller and I'm the 15 Engineering Supervisor responsible for the V.C. Summer 16 Subsequent License Renewal Project. By way of my 17 background, I've with the Dominion SLR team since 2017 18 and my group is responsible for the relicensing of the 19 Dominion nuclear fleet.
20 V.C. Summer is the third subsequent 21 license renewal project for us following the 22 successful North Anna and Surry Projects.
23 We appreciate the opportunity to speak 24 with the ACRS Committee today on V.C. Summer's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 application. It's a very important day and we look 1
forward to presenting the application highlights to 2
the Committee.
3 Next slide, please.
4 Here's the agenda for the discussion 5
today: I'll introduce the team here with me and 6
remotely. We'll discuss an overview of the station 7
and its performance; the development of the subsequent 8
license renewal application; a few technical topics 9
and closing remarks.
10 Next slide.
11 I'd like to introduce the team assembled 12 here with me today.
13 With me to my right is Beth Jenkins, the 14 V.C. Summer Site Vice President. Beth joined the 15 Dominion family in January, and previous to that, she 16 was the plant manager at Watts Bar, and then, 17 Sequoyah.
18 Chuck Tomes is at the table to my left.
19 Chuck is an SLR Technical Lead and he will be speaking 20 on one of the topics today.
21 Pratt Cherry, our SLR team mechanical 22 lead, is at the end here.
23 With us on the Teams link is Richard 24 Burtt. Richard is the Manager of Nuclear Site 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 Engineering and will also be presenting a technical 1
topic.
2 Although he can't be with us today, I want 3
to recognize Calvin Pugh. Calvin is the Director of 4
the Subsequent License Renewal Organization.
5 We also have several team members and 6
corporate and station leaders in the audience here in 7
the room.
8 James Holloway, who is the Vice President 9
of Nuclear Engineering, is here, and the SLR 10 organization falls under James' purview.
11 And Brenda Brown is here. Brenda is the 12 Director of Nuclear Engineering at V.C. Summer.
13 Last, but not least, Roger Rucker is here.
14 Roger is the electrical engineering lead for the 15 Subsequent License Renewal Project.
16 We also have numerous technical staff from 17 Dominion and Westinghouse available in the virtual 18 audience, should we need some assistance on any 19 questions the Committee may have. If needed, they'll 20 identify themselves and address your questions.
21 And with that, I'll turn the presentation 22 over to Beth Jenkins to discuss an overview of the 23 station.
24 MR. SUNSERI: If I might interject, we're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 going to interrupt you a lot here today. So, I 1
apologize in advance for that.
2 But I just want to say, you mentioned an 3
impressive commitment by your company to bring these 4
resources here like this. And to us, you know, 5
sometimes we don't want to be a burden, but we want to 6
fulfill our obligation as well.
7 But to see this kind of support gives us 8
a good feeling of how important this is to you and the 9
care you put into these programs. I just wanted to 10 highlight that before you get too far into it.
11 MS. JENKINS: Thank you.
12 And good morning, everyone.
13 I'm Beth Jenkins. I'm the Site Vice 14 President of V.C. Summer Nuclear Station.
15 We're going to start today with an aerial 16 view of the station. I'm going to highlight some of 17 the more significant features to help the Committee 18 get oriented.
19 To the north of the station is the 20 Monticello Reservoir. One unique aspect of the 21 Monticello Reservoir is that it not only serves as a 22 source of makeup cooling water for V.C. Summer, but 23 also serves as the upper pool for the Fairfield Pump 24 Storage Facility.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 You can see the Fairfield Pump Storage 1
Facility in the upper left here, and the Parr 2
Reservoir serves as the lower reservoir for the Pump 3
Storage Facility. And that can be partly seen to the 4
left.
5 The reactor building is in the center of 6
the circle, and the service water pond lies just to 7
the east. And we'll be discussing the service water 8
pond in a
little more detail later in the 9
presentation. The switch yard is just to the south.
10 Next slide, please.
11 This slide lists a few of the significant 12 milestones in the station's history. A few of them 13 were mentioned earlier in the presentation.
14 V.C. Summer was originally licensed in 15 1982 for 2775 megawatts thermal and uprated to 2900 16 megawatts thermal was approved in 1996.
17 In 2004, the operating license was renewed 18 the first time.
19 The station entered the first period of 20 extended operation in the fall of 2022.
21 The current license which we're seeking to 22 renew a second time expires in 2042. So, renewal will 23 permit station operation to 2062.
24 Next slide, please.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 V.C. Summer is a three-loop Westinghouse 1
pressurized water reactor. The unit operates on an 2
18-month refueling cycle.
3 As far as regulatory status, V.C. Summer 4
is in column 1 of the reactor oversight process 5
actions matrix, and all ROP indicators are green.
6 At the bottom is a brief table that 7
summarizes the station's capacity factors over the 8
last five years. And I'll just mention that the 9
outliers are predominantly driven by whether or not we 10 had a refueling outage that year or extended outages.
11 MEMBER PALMTAG: Thanks for anticipating 12 that question. Because when I looked at the numbers, 13 they looked a little off.
14 MS. JENKINS: Varied?
15 MEMBER PALMTAG: Yes. Varied, yes. I 16 wasn't sure if that was all due to -- so, the 17 refueling outages were longer than the (audio 18 interference)?
19 MR. MILLER: Correct. Yes.
20 MEMBER PALMTAG: Okay.
21 MR. MILLER: The lower capacity factors 22 are if we extended --
23 MEMBER SUNSERI: I'm sorry, Keith, you 24 need to use your mic and introduce yourself for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 court reporter each time you speak.
1 MR. MILLER: Thanks for that reminder.
2 Yes, my name is Keith Miller. I'm the SLR 3
Supervisor.
4 Yes, the lower capacity factors were 5
primarily due to extended outage, an outage longer 6
than (audio interference).
7 MEMBER PALMTAG: And why were they 8
extended?
9 MR. MILLER: Well, if you look, in 10 particular, at the 2021 capacity factor rated 2.69, 11 that outage was extended about 25 days due to a main 12 transformer fire. So, that was the main contributor 13 there.
14 MEMBER PALMTAG: Okay.
15 MEMBER PETTI: Question. This is Dave.
16 How do you get a capacity factor over 100?
17 (Laughter.)
18 You operated above your --
19 MS. JENKINS: No, so we had no outage that 20 year, no refueling outage that year.
21 (Laughter.)
22 MEMBER PETTI: Okay.
23 MS. JENKINS: And the factor is based on 24 our maximum dependability capacity and that is based 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 on lake temperature of 85 degrees. So, if we're less 1
than 85 degrees, we have increased efficiency.
2 MEMBER PETTI: Thanks.
3 MS. JENKINS: Next slide.
4 V.C. Summer has continued to invest in the 5
safety, reliability, and long-term operation of the 6
station. And this slide shows some of the significant 7
plant upgrades that have been performed since initial 8
license renewal. Many of these upgrades support 9
improved aging management of the station's system, 10 structures, and components.
11 We intend to make similar investments as 12 we approach the subsequent period of extended 13 operation and will continue to make investments to 14 ensure the safety and reliability of the plant.
15 Now, I'll turn the presentation back over 16 to Keith to discuss the subsequent license renewal 17 application.
18 MR. MILLER: Thank you.
19 In the next few slides, I would like to 20 discuss how the subsequent license renewal application 21 was built and some high level results.
22 The V.C. Summer Subsequent License Renewal 23 Project is the third for Dominion Energy. Many of our 24 project team members have remained with us since 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 Surry. And in addition, many of our staff have 1
experience on the Dominion initial license renewals 2
and experience from other utilities' license renewal 3
projects. That depth of experience has been 4
invaluable in our efforts to build a high quality 5
application.
6 We've been active participants in the 7
Nuclear Energy Institute License Renewal Task Force 8
over the years. And we've also participated in 9
several peer reviews of other subsequent license 10 renewal applications.
11 VICE CHAIR HALNON: Keith, this is Greg.
12 Since the company, or the plant changed 13 hands from the license renewal to the subsequent, did 14 you have any original members of the license renewal 15 team on the subsequent license renewal team?
16 MR. MILLER: We didn't, actually, not from 17 the initial V.C. Summer license renewal. None of 18 those folks transitioned over to our team.
19 VICE CHAIR HALNON: How did you translate 20 that deep knowledge that those folks have to the plant 21 over the last 20-30 years to the subsequent license 22 renewal team?
23 MR. MILLER: Yes, I would say it wouldn't 24 necessarily be deep knowledge of the station itself, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 but knowledge of the license renewal process and how 1
to build applications and get through the reviews, 2
things like that.
3 VICE CHAIR HALNON: Okay. But you still 4
have to have experienced input into the process. And 5
I get the process piece, but was the application 6
produced in Richmond or was it produced in 7
Jenkinsville?
8 MR.
MILLER:
So, we produced the 9
application in Richmond. But I'll say that we've had 10 great participation with our station partners 11 throughout the process.
12 We started the project in the summer of 13 2021. And in the fall of 2021, we started writing 14 aging management programs. Those aging management 15 programs were reviewed and commented on between us and 16 the program owners. Because they're closest to the 17 programs, we want to understand the OE like they 18 understand it on a daily basis.
19 VICE CHAIR HALNON: Having the program 20 managers from the site into the process?
21 MR. MILLER: Correct, correct. Every 22 aging management program that we wrote was concurred 23 on by the program owner at the site.
24 VICE CHAIR HALNON: Just top of the head, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 was it a significant change from the control, from 1
SCE&G style to the Dominion style? In other words, 2
did you have to do a complete rewrite of those 3
programs or was it pretty close?
4 MR. MILLER: Yes, so V.C. Summer the first 5
time around was GALL Rev 0. So, generally, the 6
approach we've taken for all three stations was to 7
pretty much start from scratch. We used the initial 8
license renewal documentation, certainly, as we were 9
doing our research, but we found it's been more 10 efficient just to start from a clean sheet of paper.
11 VICE CHAIR HALNON: There's some value in 12 that, too.
13 MR. MILLER: Yes.
14 VICE CHAIR HALNON: Thanks.
15 MR. MILLER: Okay. The application was 16 built with an eye towards maximizing consistency with 17 the regulatory and industry guidance. And in 18 constructing the application, we performed several 19 benchmarking activities.
We looked at other 20 subsequent license renewal applications and 21 correspondence between the NRC and the applicants, 22 such as requests for additional information and 23 supplement letters, and incorporated any learnings 24 there. We built on our experience with North Anna and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 Surry and attempted to incorporate any lessons learned 1
from those NRC reviews.
2 And just as evidence, the application 3
quality has been steadily increasing. The number of 4
requests for additional information that we received 5
during the NRC review has steadily decreased from 6
Surry to North Anna, and now to V.C. Summer.
7 Also, we conducted a peer review of our 8
subsequent license renewal application to gather any 9
insights from our industry peers.
10 Next slide, please.
11 On this slide, I would like to discuss 12 some of the high level results.
13 First, in the area of aging management 14 reviews, we did achieve high consistency with the 15 GALL. Greater than 99 percent of the AMR items 16 utilized the standard notes.
17 In the area of operating experience, we 18 reviewed 10 years' worth of operating experience, such 19 as Condition Reports, for aging-related insights.
20 A self-assessment was performed in 2021, 21 as the station prepared for the IP-71003 inspections 22 prior to entering the first period of extended 23 operation. And then, once the 71003 inspection was 24 performed, the report documented no findings or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 violations.
1 In the area of aging management programs, 2
there are 49 programs for SLR, which we'll talk about 3
a little bit on the next slide.
4 This slide summarizes the various 5
categories of aging management programs and their 6
respective consistency with GALL. Roughly 20 percent 7
of the population are new AMPs. Just under half of 8
the aging management programs are consistent with 9
GALL, and five of the new programs are in the 10 electrical area.
11 Next slide, please.
12 There were several technical topics that 13 we would like to briefly discuss, based on requests 14 from the Committee.
15 The first is the service water pond 16 configuration and any aging management activities 17 related.
18 The second is related to emergency diesel 19 generator performance.
20 And the third is primary shield wall 21 fluence and vessel support inspections.
22 Next slide.
23 So, the first topic we'll address is the 24 service water pond configuration and then, aging 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 management activities related to it.
1 The service water pond is a safety class 2
impoundment of about 41 acres within a small arm of 3
the much larger Monticello Reservoir, which is about 4
6800 acres.
5 The photo on the left shows a zoomed-out 6
view to give you a decent feel for the orientation, 7
and the photo on the right is a more closeup view.
8 The pond was formed by using a portion of 9
the Monticello Reservoir shoreline, the west 10 embankment, and utilized to higher elevation natural 11 areas close to the shoreline. And these natural areas 12 can be thought of as islands, if they weren't 13 connected as they are now.
14 Three small earthen dams were built which 15 connect the west embankment to the two raised natural 16 areas. The north dam is there where the pointer is.
17 The east dam is there, the L-shaped, and the south dam 18 is there. And that forms the perimeter of the pond 19 that separates it from the Monticello Reservoir.
20 And as mentioned on the site overview 21 slide, the reservoir serves as the upper pool of the 22 Fairfield Pump Storage Facility. And due to that 23 facility's normal operations, the water level in the 24 reservoir could fluctuate up to 4.5 feet. So, the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 service water pond boundary enclosure serves to 1
maintain a consistent water level and volume in the 2
pond during the normal fluctuations of the reservoir.
3 Next slide, please.
4 VICE CHAIR HALNON: And I suppose it goes 5
without saying that you're in a (audio interference),
6 right?
7 MR. MILLER: Correct.
8 VICE CHAIR HALNON: Good assuming.
9 MR. MILLER: This slide lists several of 10 the aging management activities that are being 11 performed for the service water pond. Dams and 12 embankments are inspected for erosion, movements, 13 surface cracks, sloughing, et cetera, on an annual 14 basis. Dam elevation, alignment, and slope surveys 15 are conducted every five years.
16 Two bottom elevation surveys have been 17 performed in the past to monitor the extent of 18 sedimentation in the pond. And we have created an 19 enhancement to the water control structures aging 20 management program to conduct those sedimentation 21 surveys periodically moving forward.
22 And last, the Federal Energy Regulatory 23 Commission, or FERC, inspects the dams every three 24 years.
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28 MEMBER BIER: A quick question this slide.
1 This is Vicki here.
2 When you say, "embankments inspected," I 3
assume that covers kind of natural earth embankments 4
as well as constructed dams and levees, is that 5
correct?
6 MR. MILLER: That's correct.
7 MEMBER BIER: Okay. Thank you.
8 MEMBER MARTIN: So, Keith, can you go back 9
to the previous slide?
10 MR. MILLER: Sure.
11 MEMBER MARTIN: Can you speak to the 12 chemistry control in the service water pond?
13 MR. MILLER: Yes. Well, I'm going to 14 actually turn to April Rice in the V.C. Summer 15 Conference Room.
16 April, can you provide a little input on 17 that? The question was related to chemistry control 18 in the service water pond.
19 You have to take yourself off mute.
20 MS. RICE: Thank you.
21 This is April Rice.
22 Let us get to the chemist and we'll get 23 right back to you with that response.
24 MEMBER MARTIN: Okay. Thank you.
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29 MS. RICE: Okay.
1 VICE CHAIR HALNON: So, while we're on 2
this picture, I realize the islands, or whatever you 3
call them, are not constructed earthen dams, but are 4
those inspected as well when you do the inspection?
5 MR. MILLER: Islands are inspected as 6
well.
7 VICE CHAIR HALNON: Okay. And how often 8
-- I'm sorry -- how often was the inspection?
9 MR. MILLER: Five-year frequency.
10 VICE CHAIR HALNON: Okay. And the 11 qualifications of the people who would do those 12 inspections, can you speak to that?
13 MR. MILLER: I'm going to actually ask 14 Judd Ruth from V.C. Summer to answer that question.
15 And the question was, qualifications related to the 16 folks doing the inspections of the service water pond 17 structures.
18 MR. RUTH: Yes. This is Judd Ruth at V.C.
19 Summer. I'm a civil engineer with the design 20 engineering team.
21 Yes, we have professional engineers, 22 PE-licensed folks who oversee those inspections, along 23 with other civil engineers that have experience with 24 doing those inspections.
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30 MR. MILLER: Thanks, Judd. And greetings 1
to all you folks back in the conference room.
2 When I looked at the qualifications 3
required, PE was one of them, civil engineering, 4
graduated from an ABET school, 10 years of concrete 5
structure experience, and ASR qualifications. Is that 6
consistent with what you would say is your qualified 7
folks? ASR is Alkali-Silica Reaction.
8 MR. RUTH: Yes.
9 MR. MILLER: Okay.
10 MR. RUTH: Yes. This is Judd Ruth again.
11 As far as the embankments, there's no 12 concrete really involved with those inspections. So, 13 I wouldn't say that that applies to the earthen 14 portions. But, yes, if we do concrete inspections, 15 that would be a qualification.
16 MR. MILLER: Right.
17 VICE CHAIR HALNON: And I don't think it 18 gives you a choice, I think if your Code requires 19 those for the inspectors. So, I'd suggest you go back 20 and look and make sure that, if you do have an 21 exception, it's at least acknowledged and you 22 understand how it goes.
23 MR. MILLER: So, any more questions on the 24 service water pond?
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31 VICE CHAIR HALNON: One last question is, 1
can you address a potential failure of the Monticello 2
earthen dam? How does that affect the service water 3
pond? How does it maintain its water level?
4 MR. MILLER: Yes. So, the service water 5
pond boundary enclosure is designed that, if we lose 6
the dams that form the Monticello Reservoir, the 7
service water pond structure will be not impacted. It 8
will maintain water level. Those dams are designed to 9
maintain level, even with total loss of the Monticello 10 Reservoir.
11 VICE CHAIR HALNON: So, for lack of a 12 better term, it's got to be checked-off?
13 MR. MILLER: Correct. Correct.
14 VICE CHAIR HALNON: And the Monticello 15 dams, are they inspected to the same frequency, just 16 for convenience's sake, or are they inspected by FERC 17 at all?
18 MR. MILLER: I'll ask Judd Ruth again.
19 The question was related to inspections of the 20 Monticello Reservoir dams, the periodicity.
21 MR. RUTH: Yes, this is Judd Ruth from 22 V.C. Summer design engineering.
23 Yes, FERC does inspect those or does 24 inspect the Monticello dam. As far as the frequency, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 that is controlled by corporate folks and we don't 1
control those inspections.
2 VICE CHAIR HALNON: Okay. That's similar 3
to other earthen dams, that they're on the FERC 4
cycles.
5 MEMBER HARRINGTON: This is Member 6
Harrington.
7 Just the inspections and the frequency, 8
all that, has that changed because of initial or 9
subsequent license renewal, or has that been the case 10 throughout plant life or?
11 MR. MILLER: I can't speak to plant life, 12 but it has not changed during the subsequent license 13 renewal and subsequent (audio interference) period.
14 VICE CHAIR HALNON: Yes, this is Greg one 15 last time.
16 I know there's a tech spec on temperature 17 probably for the pond. South Carolina is not Ohio.
18 So,
- you, obviously, get some extremely hot 19 temperatures. How do you -- have you had to derate 20 the plant or shut down, based on temperature that you 21 found in the near past? I mean, you have some really 22 hot temperatures for a couple or three years.
23 MR. MILLER: I'll turn to V.C. Summer to 24 answer that question.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 The question was related to derating due 1
to temperature in the reservoir, if that's happened in 2
the past or not.
3 MR. KEARNEY: This is Will Kearney. I'm 4
the Plant Manager at V.C. Summer Station.
5 I believe the question was about the 6
service water pond temperature limits. We do have a 7
tech spec limit on that. We have not had to derate 8
the units at any time due to challenges to that 9
temperature.
10 VICE CHAIR HALNON: Is there a spray 11 system in place just in case you have to cool it down?
12 MR. KEARNEY: We do not have a spray 13 system. That is something that we have conceptually 14 looked at in the distant past, but it is not something 15 that we have ever pursued beyond that.
16 VICE CHAIR HALNON: I see.
17 MEMBER SUNSERI: I know you're still 18 working on the question regarding the chemistry 19 control. It's my experience with configurations like 20 this that degradation mechanisms, either sediment 21 buildup or biofoulings -- I suspect that you're 22 treating the water for biofouling and checking the 23 sediment ever so often?
24 MR. MILLER: Yes. So, the sedimentation 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 surveys are performed periodically. In the past, we 1
have done two 15 years apart and we have a work order 2
to do the next one in 2027, I believe, and then, it 3
will be every 15 years, likely, ahead.
4 But, yes, it is treated for biofouling.
5 I don't have the specifics on the chemistry control.
6 So, I don't want to speak out of turn. But I do know 7
that biofouling is one of the things that we're 8
treating for in the pond and the components 9
downstream.
10 MEMBER SUNSERI: Yes. Thank you.
11 VICE CHAIR HALNON: And this is Greg.
12 The reason I asked about the chemistry is 13 it's a relatively stagnant --
14 MR. MILLER: Yes.
15 VICE CHAIR HALNON: -- set of waters. You 16 have evaporation and you have concentration in the 17 sump tank.
18 MR. MILLER: Right.
19 VICE CHAIR HALNON: And that's why I'm 20 asking about the chemistry. So, when you get that, 21 I'd appreciate the feedback.
22 MR. MILLER: So, if there are no other 23 questions on the service water pond, I'll turn it over 24 now to Richard Burtt, on the virtual line, to discuss 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 the second technical topic, which is emergency diesel 1
generator performance.
2 MR. BURTT: All right. Good morning.
3 I'm Richard Burtt. I'm the Nuclear Site 4
Engineering Manager here at V.C. Summer.
5 I'll discuss our emergency diesel 6
generator performance, specifically, on the topic 7
related to a white performance deficiency we received 8
in 2022 associated with failure to identify and 9
correct conditions adverse to quality, specifically, 10 on our fuel system piping and cracks in the threaded 11 portion of that piping.
12 The direct cause was cracking in a 13 Schedule 40 threaded pipe circumferentially during a 14 24-hour run. And then, our regulator, looking back, 15 said we had identified opportunities we had previously 16 had to identify cracking vulnerability and could have 17 corrected it during prior maintenance activities.
18 So, we performed a root cause on this 19 former deficiency and the event. We identified two 20 root causes.
21 First, organizationally, it was focused on 22 our Corrective Action Program. And at the time of the 23 events, our Corrective Action Program failed to derive 24 effective evaluation and resolution of the fuel piping 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 cracks in previous events.
1 And then, the second root cause was 2
associated with the fuel piping design itself being 3
Schedule 40 piping, hard connections, a black iron 4
pipe that was inadequate for mechanical adjustments 5
and allowing maintenance and causing challenges during 6
maintenance to correct leaking connections.
7 So, next slide.
8 Prior to that, we did pursue a fuel piping 9
design change. We replaced the Schedule 40 piping 10 with Schedule 80, mostly welded joints, and installed 11 first-of-the-kind-in-the-industry flexible hoses on a 12 fuel oil header. And we also included flange 13 connections to allow for ease of maintenance.
14 Related to the Corrective Action Program, 15 at the time of the previous events, we were under our 16 SCANA Corrective Action Program in the version it was.
17 We have since transitioned to our Dominion Corrective 18 Action Program. And part of that had improved some of 19 the vulnerabilities as far as what was considered 20 conditions adverse to quality. More is screened in 21 under the Dominion process.
22 But, beyond that, we also improved our 23 Corrective Action Program for any identified 24 through-wall leaks or repeat conditions to drive a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 higher-level evaluation. Those do get specifically 1
identified during our corrective -- or sorry -- our CR 2
review teams. We've also included this into our plant 3
health process to look at longstanding issues, strive 4
for resolution.
5 We also implemented a
prevention, 6
detection, and correction culture. That was mainly 7
focused to improve plant equipment reliability, but we 8
have also included it in our improvements from this 9
event. And we also have an annual review of those 10 longstanding items.
11 And just to identify, since these events, 12 we've had satisfactory surveillance runs during our 13 monthly runs.
14 And with that, I'll turn the presentation 15 to Chuck Tomes.
16 MEMBER SUNSERI: Thank you.
17 Before Chuck begins, just a question about 18 that kind of culture model. I mean, since you made 19 these changes to your Corrective Action Program, do 20 you have any notable example of where, outside of the 21 diesel generator fuel oil system, where you --
22 COURT REPORTER: This is the court 23 reporter. Could I ask the person posing the question 24 to identify himself for the record?
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38 MEMBER SUNSERI: Sunseri.
1 I lost my train of thought.
2 Okay. So, any notable examples of where 3
you, for lack of better words, connected the dots on 4
screening, maybe minor problems that were leading to 5
bigger problems, like this one with the diesel 6
generator? Any examples of where your culture 7
improved in that area?
8 MR. KEARNEY: This is Will Kearney again, 9
the Plant Manager.
10 It is a diesel generator example, but it's 11 not fuel-piping-related. We did take the opportunity 12 to replace the OEM jacket water piping on the 13 emergency diesel generator. These are Fairbanks Morse 14 engines. The OEM design employs a partial penetration 15 butt weld type of assembly for that, for all those 16 jacket weld or jacket water piping.
17 There was industry OE on through-wall 18 leakage on that jacket water piping. Our peer station 19 under Dominion Millstone Power Station had addressed 20 that at their end by replacing that with full-pin 21 jacket weld piping that they fabricated at their 22 facility. So, based on that OE and on their 23 experience with manufacturing it, we proactively 24 fabricated and replaced all of our jacket water piping 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 to preclude a jacket water through-wall leak at 1
service station diesels.
2 MEMBER SUNSERI:
Thanks for those 3
examples.
4 I know I'm preaching to the choir here, 5
but when a plant runs as good as yours appears to be 6
running over the years, it's very important to be able 7
to connect the dots on these lower-level issues to 8
prevent them from turning into bigger issues --
9 maintaining high reliability and safety. And it looks 10 like you're doing it correctly.
11 MR. KEARNEY: Thank you.
12 CHAIR KIRCHNER: So, Keith, let me ask you 13 a question to follow up on Matt's.
14 Since you are taking the corporate view on 15 this SLR, did you go back to North Anna and Surry and 16 look at the emergency diesel generators as a result of 17 what you found in Summer?
18 MR. MILLER: So, I would say that that was 19 likely looked at by North Anna and Surry, outside of 20 my organization. The V.C. Summer issues were not 21 directly aging-related, related to the fuel oil piping 22 cracking. But, as a fleet, in general, yes, when we 23 have a problem at one station, we evaluate it at all 24 the other stations for applicability and whether it --
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40 CHAIR KIRCHNER: I can't remember what 1
diesel generators are at North Anna and Surry, whether 2
they're Fairbanks Morse or not. But I'm just curious 3
to see if you want back, based on this experience, and 4
looked at your other plants.
5 MR. MILLER: Yes, it is. In general, yes, 6
it is always looked at for significant issues in our 7
fleet.
8 VICE CHAIR HALNON: So, this is Greg.
9 You said it wasn't aging-related, but it 10 exists since 2004, which would make it almost 20 years 11 old. It sounds aging to me.
12 MR. MILLER: Yes, so it was primarily 13 piping configuration and there were a lot of 14 mechanical joints in the piping and they were leaking 15 from the mechanical joints. So, as fixes were made in 16 the past, it disturbed other joints and leaking issues 17 occurred. But not a direct aging-related mechanism.
18 CHAIR KIRCHNER: But wait a minute, 19 though. Let's pull the string on this a little bit 20 there.
21 I mean, these diesel generators vibrate.
22 I mean, you get a lot of -- your fix here, obviously, 23 the flexible piping is a good way to isolate the 24 vibrations and the fatigue that comes with that for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 things like diesel generators. Because those things, 1
you know, the way you cycle them to test them, the way 2
they vibrate, I mean, that puts aging in all those 3
joints.
4 MR. MILLER: Correct. And the solution I 5
think that the station implemented is a
6 fix-it-forever, hopefully, solution that we look to 7
do, if possible.
8 MEMBER SUNSERI: Go ahead.
9 MR. TOMES: Good morning. My name is 10 Chuck Tomes.
11 And I want to thank you for reviewing the 12 V.C. Summer --
13 VICE CHAIR HALNON: I'm sorry. Before we 14 get off of the diesel generator, I thought there was 15 another slide that we were going to see with the 16 pictures.
17 In 2022, you had another diesel generator 18 problem for an erratic governor. I can't remember if 19 it went into a white finding or not, but it was 20 definitely at least a (audio interference) issue.
21 What kind of confidence can you give us 22 that the program -- if you don't want to call it 23 "aging," I'm good with that -- but the program to 24 monitor the health of the diesel generators is strong?
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42 Because for about four years, you had degraded diesel 1
generators. And it kind of shakes the confidence that 2
the diesel systems are being watched over and being 3
carefully taken care of.
4 So, how can you provide us better 5
confidence that that's all taken care of?
6 MR. TOMES: Yes, thank you for the 7
question.
8 I think that we would look back at 9
Richard's previous slides on the corrective actions 10 that were taken following the events, plural, with the 11 diesel generator.
12 VICE CHAIR HALNON: Okay. So, you're kind 13 of blaming the old scam of corrective action process 14 and culture in some ways, saying that the new one 15 fixes it. In that case, what about the other safety 16 systems that came under the V.C. Summer old Corrective 17 Action Program for years?
Did you take a
18 comprehensive look back at all the corrective actions 19 and problems for years to make sure that it's not 20 latent problems that are just sitting out there 21 waiting for the next failure to do an extended 22 condition?
23 MR. TOMES: I'd ask, Richard, could you 24 speak to any extent-of-condition, extent-of-cause 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 initiatives that were performed as a result of the 1
diesel generator issues, not necessarily with the 2
diesels, but outside those particular systems?
3 MR. BURTT: Yes. Again, this is Rich 4
Burtt from V.C. Summer, Site Engineering Manager.
5 So, kind of backing up a little bit to 6
this
- question, specifically, with the diesel 7
generators, we have taken a harder look at their 8
reliability.
We have performed third-party 9
vulnerability reviews and we are in the midst of 10 k i c k i n g o f f a
s u b s t a n t i a l,
11 down-to-the-subcomponent-level vulnerability deep dive 12 on those diesels that should take us about three to 13 four months to find vulnerability opportunities to 14 improve and prevent any future failures.
15 As far as extended condition and extended 16 cause out of this event, we did go to the other safety 17 systems. We covered all the mitigating systems as far 18 as condition related to Schedule 40 or threaded 19
- piping, but also with the
- cause, we did a
20 comprehensive review of conditions on each of those 21 systems for any trends or anything identified, load 22 level, that could indicate we had not evaluated 23 strongly enough under our previous program.
24 Also related to
- this, all of our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 performance deficiencies were reviewed under a common 1
cause analysis for the whole station, that then drove 2
further improvements.
3 VICE CHAIR HALNON: Thanks, Richard.
4 And again, in Matt's words, I'm kind of 5
preaching to the choir. I always had felt that very 6
strong indication of plant safety and how well the 7
system is being taken care of are the number of 8
self-reviewing violations or findings and/or issues 9
that come up. Because those are the latent issues 10 that just, they fail; something happens.
11 So, I would suggest that, if you haven't, 12 to go back and look at the self-revealed problems over 13 the last however many years and make sure that you 14 have really investigated those to the point where 15 you're satisfied that in your new program/new culture, 16 looking at corrective actions, it's satisfactory, 17 especially the diesels.
18 I mean, it sounds like you failed the 19 diesels. Just looking at Schedule 40 pipe throughout 20 the plant is a good thing, but it's pretty narrow, 21 when you come up with statements like the Corrective 22 Action Program and plant health process have changed.
23 And that's what the bullet on the slide says, that 24 it's one of the things of how we fixed it.
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45 So, I just want to, again, make sure that 1
the diesel, like the other safety systems, are poised 2
to go forward.
3 And it's not a critique, but a lot of 4
times in front of the Committee, when we're talking 5
about a specific component, it speaks volumes if you 6
have that system engineer speak to the ownership of 7
that system. Because I've noticed it's, you know, 8
Plant Manager, Engineering Managers talking. And it 9
would be really nice to hear from the system engineer 10 who takes care of the diesels. Just a little coaching 11 there, not that you're going to get a subsequent 12 license renewal program again. Maybe in the future 13 plants. It does speak volumes to have the actual 14 owner talk to the points.
15 Thanks.
16 MEMBER SUNSERI: We are falling behind.
17 It's not your fault; it's our fault. We're asking a 18 lot of questions. But just keep that in mind. Thank 19 you for your patience.
20 MR. TOMES: Thank you for reviewing the 21 V.C. Summer SLR application. We appreciate it.
22 The next technical topic we'd like to 23 discuss is assessment of the primary shield wall and 24 reactor vessel supports due to radiation dose.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 The way we approached that was to contract 1
with Westinghouse Electric Company to create an 2
integrated fluence model for assessment of the reactor 3
vessels internals, the reactor vessel direct vessel 4
structural integrity, the concrete biological shield, 5
and our reactor vessel supports.
6 The model uses inputs from both in-vessel 7
and ex-core dosimetry. The fluence model is an 8
extension of the NRC-approved Reg Guide 9
1.190-compliant model used for assessing the reactor 10 vessel for P-T curves, P-TS, and upper shelf energy.
11 This slide illustrates the configuration 12 of the primary shield wall relative to the reactor 13 vessel supports in the reactor pressure vessel.
14 Assessment of reduction of strength in 15 mechanical properties due to radiation for the primary 16 shield wall and reactor vessel supports is documented 17 in the SLRA Section 3.5.2.2.2.6, as amended in 18 Supplement 4.
19 The assessment shows that the level of 20 neutron and gamma dose to the primary shield wall and 21 reactor vessel supports are in excess of the screening 22 criteria. The primary shield wall was evaluated to 23 assess the radiation effects. For regions where the 24 dose threshold levels are exceeded, the concrete was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 not credited in the structural evaluations or 1
assessment of SLR.
2 This evaluation demonstrated that the 3
primary shield wall will maintain a structural 4
integrity and perform its current licensing basis 5
design functions in excess of 80 years. During the 6
subsequent period of extended operation, the primary 7
shield wall will be monitored under the structures 8
monitoring program at a frequency of every five years.
9 For assessment of the reactor vessel 10 supports, the analysis uses design basis loads and 11 does not consider the reductions that would be 12 considered with leak-before-break approvals. The 13 various portions of the metal supports are 14 flaw-tolerant due to either the stress levels being 15 lower than the critical stresses or the potential 16
- defects, such as postulated defects that are 17 incorporated into a flaw tolerance evaluation, are 18 less than the critical flaw sizes.
19 During the subsequent period of extended 20 operation, at least one of the six reactor vessel 21 supports will be inspected on a five-year frequency 22 under the ISI Section 11 IWF Program, and all six of 23 the reactor vessel supports will be inspected on a 24 10-year frequency under the ISI Section 11 IWF 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 Program. The reactor vessel supports were most 1
recently inspected during the 2024 refueling outage 2
with acceptable results.
3 If there are no questions, I'll turn it 4
back over to Keith.
5 MEMBER SUNSERI: So, the inspection 6
results you are seeing, how would you characterize 7
that? I mean, is that significant degradation, not 8
significant degradation?
9 MR. TOMES: There is no degradation been 10 detected on metal supports.
11 MEMBER SUNSERI: Yes, I thought you said 12 there were some flaws that you picked up.
13 MR. TOMES: No, in the fracture mechanics 14 evaluation, we postulate a flaw, and then, we grow it 15 over the 80-year time period to see if it will reach 16 the stability criteria.
17 MEMBER SUNSERI: Got it. Got it, yes.
18 MR. TOMES: It's to ensure that, if 19 there's an undisclosed flaw that we hadn't considered, 20 it won't grow to the level where it would compromise 21 the structure.
22 MEMBER SUNSERI: So, in light of these 23 analyses, you have not seen any degradation then?
24 MR. TOMES: Correct.
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49 MEMBER SUNSERI: Because of the low 1
margin, you're monitoring them?
2 MR. TOMES: Yes.
3 MEMBER SUNSERI: Is that a way of 4
characterizing it?
5 MR. TOMES: Well, we have calculated the 6
margins, and I wouldn't say that they're low. But, 7
coincidentally, we have aging management programs that 8
look at these reactor vessel supports anyway. And 9
we're ensuring that we perform inspections that are 10 consistent with what we would want to take credit for 11 under the SLR aging management program for structures 12 monitoring, which is that five-year frequency. So, 13 we've enhanced our program to increase the frequency 14 of inspection that was being performed every 10 years 15 to ensure that we also perform an inspection on a 16 five-year frequency.
17 MEMBER SUNSERI: That's helpful. Thank 18 you.
19 CHAIR KIRCHNER: May I follow up, Chuck, 20 and ask you? So, what did you find in your 21 inspections about -- obviously, you were looking in 22 and around the concrete. So, what does the concrete 23 look like in terms of assessing that, even though you 24 don't credit that in the support of the vessel?
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50 MR. TOMES: Much or some of the concrete 1
on the ID surface of the primary shield walls is 2
difficult to see, but we use fluoroscopes and we 3
inspect the reactor vessel supports. And we look at 4
the concrete adjacent to the supports. And if we 5
detect -- we haven't found any level of cracking at 6
all. And the practice would be, if we had any 7
degradation in the grout adjacent to the reactor 8
vessel support structure, we would provide that 9
information to our structures monitoring engineers 10 through the Corrective Action Program, and they would 11 evaluate it.
12 CHAIR KIRCHNER: Thank you.
13 MEMBER BALLINGER: This is Ron Ballinger.
14 I might add that, with respect to the 15 concrete, historically, there was a thought originally 16 that there would be significant irradiation effects, 17 but that data originally was from places where they're 18 completely non-representative and there was this 19 fall-off and everything. And it resulted in a program 20 to do a lot of research and everything related to 21 concrete degradation because irradiation effects.
22 But, eventually, we've discovered or 23 realized that, when you get new data, that there 24 really isn't an issue with them. And so, the NRC 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 ultimately dropped it.
1 CHAIR KIRCHNER: No, but I wasn't going 2
there so much on the irradiation. Just the concrete 3
condition. You know, any moisture getting in there 4
and such --
5 MEMBER BALLINGER: Yes.
6 CHAIR KIRCHNER: -- and then, interacting 7
with the supports, et cetera. So, I got the answer I 8
was looking for.
9 MR. SCHULTZ: Chuck, this is Steve 10 Schultz.
11 You mentioned the Westinghouse 12 calculations associated with fluence. They had 13 applied a fairly large uncertainty factor to their 14 fluence calculations, or that's what they were 15 discussing in the overall report they sent. How is 16 that applied? How has that been applied going forward 17 in your overall fluence evaluations, either to the 18 concrete or the vessel?
19 MR. TOMES: Thank you for the question.
20 Yes, we did calculate the uncertainty for 21 the radiation model that's used for the reactor 22 vessel, the concrete biological, and the reactor 23 vessel supports. The areas that are adjacent to the 24 reactor vessel have a calculated uncertainty, in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 accordance with the methods used in Reg Guide 1.190, 1
of about 20 percent, while the area up where the 2
reactor vessel supports are located have an 3
uncertainty of about 25 percent.
4 So, we have increased the radiation 5
support or radiation that's been calculated in those 6
regions by 20 percent and 25 percent to be consistent 7
with the uncertainty in the models. In addition to 8
that, there's fuel on the outside of the periphery, 9
and we've increased the dose there by 10 percent. So, 10 we believe that the models that we're using are 11 conservative.
12 MR. SCHULTZ: And with those adjustments, 13 it allows you to operate beyond 80 years?
14 MR. TOMES: That's correct.
15 MR. SCHULTZ: It would allow you?
16 MR. TOMES: That's right.
17 MR. SCHULTZ: Thank you.
18 MR. TOMES: The reactor vessel supports 19 are flaw-tolerant and the region of the primary shield 20 wall that has radiation levels in excess of the limits 21 has been discounted in our calculations, and the 22 unaffected region of the primary shield wall is 23 adequate for curing the loads to the reactor vessel 24 during all design basis transients.
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53 CHAIR KIRCHNER:
Thanks for the 1
description.
2 MEMBER SUNSERI: Members, any other 3
questions?
4 CHAIR KIRCHNER: May I change topics, 5
Matt?
6 MEMBER SUNSERI: Sure.
7 CHAIR KIRCHNER: I just note it was 8
mentioned that there are five AMPs added in the 9
electrical area. Could you just explain what they 10 were and what the focus of those was and why you added 11 them?
12 MR. MILLER: Yes. So, the five new AMPs 13 came in with the SLR GALL.
14 CHAIR KIRCHNER: Right.
15 MR.
MILLER:
There's an AMP for 16 connectors, high voltage insulators, insulation for 17 I&C cable, insulation for low voltage cable, and --
18 what's the fifth, Roger? The fifth new AMP?
19 MR. RUCKER: The fuse holders.
20 MR. MILLER: Fuse holders. Fuse holders.
21 So, those were, as the GALL evolved --
22 CHAIR KIRCHNER: Right. Okay.
23 MEMBER ROBERTS: Hey, this is Tom Roberts.
24 I had a followup question.
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54 Did you evaluate whether any of those 1
programs should be instituted sooner than six months 2
prior to the period of extended operation?
3 MR. MILLER: So, we did a 10-year OE 4
search. And we really didn't see much related to 5
those programs. So, you know, implementation will be 6
a project down the line. But based on the OE that we 7
saw in our 10-year scrub, I don't think that they need 8
to be implemented tomorrow.
9 MEMBER ROBERTS: Okay. Thank you.
10 Yes, the one that jumped out at me is it 11 said, the procedure is being revised with regard to 12 inspecting the water it required, the in-scope 13 manholes after event-driven occurrences, such as heavy 14 rain, rapid thawing of ice and snow or flooding.
15 That just seems like good practice, good 16 housekeeping. I'm wondering if you're already doing 17 that.
18 MR. MILLER: The station is. Yes, they're 19 already --
20 MEMBER ROBERTS: So, this is formalizing 21 what you're already doing?
22 MR. MILLER: Correct. Yes.
23 MEMBER ROBERTS: Okay. Thank you.
24 MR. MILLER: It's to bring it up to what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 the GALL standard is.
1 MEMBER ROBERTS: Yes. Thank you. That's 2
helpful.
3 MEMBER SUNSERI: Maybe to tag onto Tom's 4
question, I would assume -- maybe I shouldn't do that 5
-- but maybe say presume that, if you identify any 6
issues through your Corrective Action Program, through 7
performance monitoring of the station going forward, 8
perhaps it would bring you back to (audio 9
interference) in this area. Is that fair?
10 MR. MILLER: That's fair.
11 MEMBER SUNSERI: Okay. Thanks.
12 CHAIR KIRCHNER: So, in that OE scan that 13 you conducted, Keith, did you find anything that rose 14 to your attention that required additional focus or --
15 MR. MILLER: There were several items.
16 So, the OE search we did was quite exhaustive. We 17 started with several thousand Condition Reports that 18 we went through.
19 Not necessarily in the electrical area, 20 but one of the key things that we looked for in 21 mechanical fluid systems is evidence of recurring 22 internal corrosion, where you get pinhole leaks on a 23 section of piping repeatedly.
24 CHAIR KIRCHNER: Right.
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56 MR. MILLER: We created an enhancement in 1
an open cycle cooling water system, after we 2
identified recurring internal corrosion in one section 3
of piping there, to retire that piping from service, 4
because it's no longer used for coolers.
5 But there were other, there were a couple 6
other instances of recurring internal corrosion that 7
we identified and were able to either mitigate with 8
existing activities to the stationary new valve, such 9
as the Fire Protection Program piping replacement 10 campaign, or something new, like the open cycle 11 cooling water connect that we took.
12 CHAIR KIRCHNER: That was the next one I 13 was going to ask. So, how is the fire protection 14 system? At your other sites, that was one of the 15 items that kind of rose to the prominence in terms of 16 needing attention. How is it here at the Surry plant 17
-- or at the Summer plant?
18 MR. MILLER: So, for V.C. Summer, we have 19 had some pinhole leak issues in aboveground fire 20 protection piping. And the station is actually 21 undergoing a piping replacement/valve replacement 22 campaign now, where they're taking sections of the 23 system and replacing it. So, that is an ongoing 24 activity that we've recognized in the application.
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57 CHAIR KIRCHNER: Okay. Thank you.
1 MEMBER SUNSERI: Members, anything else?
2 MEMBER HARRINGTON: This is Member 3
Harrington.
4 One of the questions earlier, you talked 5
about the transition from the initial license renewal 6
to subsequent license renewal, and, basically, 7
starting over. "Blank page" is the word used. Can 8
you clarify how much that was in the application side 9
as opposed to the plant program details? How did 10 those relate?
11 MR. MILLER: So, a big part of the new 12 content is new aging management programs that have 13 just, as the GALL evolved -- we were GALL Rev. 0 for 14 initial license renewal. So, it's two revisions of 15 GALL, plus the SLR GALL. Some of that newness was 16 introduced by just GALL revisions.
17 I'd say that, you know, a lot of the 18 enhancements that we have written for subsequent 19 license renewal are related to aligning with the SLR 20 GALL. Now, those activities might not necessarily be 21 new per se. It might be just aligning language. For 22 example, like looking for specific keywords and 23 phrases that the GALL mentions. We're doing 24 inspections for those things, but we want to enhance 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 the program to say specifically we're looking for 1
cracking, or whatever.
2 So, I guess to tie a bow on it, I'd say 3
that many of the activities are not completely new.
4 The station is doing them already. But a lot of the 5
language in the application and the aging management 6
programs is to align to the GALL.
7 MEMBER HARRINGTON: So, it wasn't so much 8
starting over with plant programs as it was just 9
cleaning up, making everything align?
10 MR. MILLER: That's correct.
11 MEMBER HARRINGTON: Thank you.
12 MR. MILLER: Okay. So, to summarize, 13 Dominion has produced a quality subsequent license 14 renewal application with a high degree of consistency 15 with the GALL Report. That leverages our learnings 16 from the previous subsequent license renewal 17 applications, both Dominion stations and fuel 18 utilities.
19 The teams highlight experience, with many 20 of our members having participated on previous 21 applications. And we intend to continue to invest in 22 people and program enhancements and station 23 modifications throughout the subsequent period of 24 extended operation. And that's going to advance the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 company's overall mission to provide reliable, 1
affordable, increasingly clean energy to our 2
customers.
3 With that, I'll close and I'll say that we 4
do have somebody from the station that's prepared to 5
answer the previous question on service water pond 6
treatment.
7 MEMBER SUNSERI: Okay. Let's go ahead 8
with that.
9 MR. RAYMOND: Hello. This is Shabazz 10 Raymond, Superintendent of Chemistry at V.C. Summer.
11 There was a question regarding our service 12 water chemical treatment. So, we do treat our service 13 water pond. We have four chemicals that we treat it 14 with. Two of them are for, basically, biological 15 control, and then, we have one which is a corrosion 16 inhibitor, and the other one is a dispersive that we 17 treat the pond with as well. And that helps keep any 18 type of silt from forming in the tubes -- the heat 19 exchanger. Excuse me.
20 VICE CHAIR HALNON: Yes, this is Greg. I 21 asked the question.
22 Part of the question was also the 23 chemistry control which includes monitoring the 24 chemistry. How often do you sample the chemistry and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 do a check on it for chlorides?
1 MR. RAYMOND: So, the chemistry, we 2
monitor it. Whenever we do chemical treatments, we 3
get samples. We monitor to see what our chlorine 4
residual is, to see what the effectiveness is for our 5
procedure, and we also obtain samples for our vendor 6
to analyze. That vendor, they analyze on that to see 7
what our phosphate concentration is, which is a 8
corrosion inhibitor that is in there. And we also 9
look at biological activity to see what that is. So, 10 if we do need to change in our regime as far as 11 increased frequency, we can do it based on that.
12 And what we're also doing is thermal 13 performance testing with engineering, and that gives 14 us a great indication of how effective our treatment 15 is. So far, we have been very successful with that.
16 VICE CHAIR HALNON: So, how often do you 17 sample for chlorides, sulfates, and pH?
18 MR. RAYMOND: So, the chlorides, sulfates, 19 and pH, that is normally done monthly and when we do 20 the other tests. They're done whenever we do the 21 chemical addition to the pond, whenever we ramp up 22 concentrations. So, if I change my strategy to three 23 days per week, based on temperature and per our 24 procedure, we'll sample it three days out of the week, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 based on those concentrations.
1 And normally, you sample your operating 2
train that you're injecting into to make sure that 3
you're seeing what you would expect from the outlet of 4
that sample, the healthy water.
5 VICE CHAIR HALNON: Okay. Thank you.
6 MR. MILLER: And just for the court 7
reporter, that was Shabazz Raymond and he's the 8
Superintendent of Chemistry at V.C. Summer.
9 MEMBER SUNSERI: Does that wrap up your 10 presentation?
11 MR. MILLER: It does.
12 MEMBER SUNSERI: Members, any additional 13 questions before we release them?
14 (No response.)
15 All right. Well, thank you for answering 16 our questions and this thorough presentation.
17 At this point, we'll transition over to 18 the NRC staff.
19 Marieliz Johnson?
20 They'll set up here in about a two-minute 21 transition period.
22 (Pause.)
23 MEMBER SUNSERI: So, we're running quite 24 a bit behind. We have five minutes.
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62 (Laughter.)
1 Just kidding. We'll grant you the full 35 2
that you're allotted. Whatever it takes, though.
3 (Pause.)
4 MS. JOHNSON: Okay.
5 MEMBER SUNSERI: All right, Mr. Chairman, 6
it looks like we're ready to resume.
7 All right. You may proceed with the staff 8
presentation.
9 MS. JOHNSON: Good morning, Chairman and 10 Members of the ACRS.
11 My name is Marieliz Johnson and I'm the 12 Safety License Renewal Program Manager, and we'll be 13 presenting on the safety review of the subsequent 14 license renewal application for Virgil C. Summer 15 Nuclear Station Unit 1, V.C. Summer for short.
16 The staff's safety review of the V.C.
17 Summer subsequent license renewal application is 18 documented on the Safety Evaluation issued on January 19 21st, 2025, and revised on March 4th, 2025, to more 20 accurately describe the Applicant's implementation 21 associated with the inspection of overhead heavy load 22 and related to refueling and handling systems.
23 Joining me today at the table are Steve 24 Downey, Region II Reactor Inspector; Mac Reed, Senior 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 Resident Inspector at V.C. Summer, and our Senior 1
Technical-Level Advisor for Aging Management, Dr. John 2
Wise.
3 Also joining us today, both in the 4
audience and virtually, are some of the Regional 5
staff, along with members of the Office of Nuclear 6
Reactor Regulations, technical staff who participated 7
in the review of the application and the associated 8
items.
9 We will begin today's presentation with an 10 overview of V.C. Summer's licensing history before 11 moving into Summer's aging management programs. We'll 12 then discuss the significant technical areas that we 13 believe is of interest to the ACRS and hear from 14 Region II on inspections completed at V.C. Summer, as 15 well as material condition of the plant. Then, we 16 will share the conclusions on the staff's safety 17 review.
18 V.C. Summer Unit 1 was initially licensed 19 in November 12th of 1982. In August of 2002, the 20 Applicant submitted an initial license renewal 21 application. The initial renewal license was issued 22 on April 23rd of 2004, extending the expiration date 23 by 20 years to August 6th, 2042.
24 On August 17 of 2023, the Applicant 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 Dominion Energy, South Carolina, Inc., submitted a 1
subsequent license renewal application for V.C.
2 Summer. The application was accepted for review on 3
October 16 of 2023 and a Safety Evaluation was issued 4
January 21st and revised on March 4th, with no open or 5
confirmatory items.
6 The V.C. Summer subsequent license renewal 7
application described a total of 49 aging management 8
programs consisting of 40 existing programs and 9 new 9
programs. This identifies the Applicant's original 10 disposition of these aging management programs, as 11 initially submitted on the application, in the left 12 column, and the final disposition, as documented in 13 the Safety Evaluation on the right.
14 All aging management programs were 15 evaluated for consistency with the GALL SLR Report.
16 Ultimately, all programs were found to be consistent 17 with the GALL Report with acceptable enhancements or 18 exceptions.
19 I'd like to also speak to the way we 20 reviewed the aging management activities and other 21 technical information in the application.
22 As part of our review, the staff conducted 23 an aging management audit to review operating 24 experience, aging management
- programs, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
65 time-limited aging analysis. The audit spanned 19 1
weeks from November of 2023 to March 2024, to include 2
both onsite and virtual activities.
3 In the audit, the staff leveraged an 4
electronic document portal and breakout sessions held 5
with the Applicant.
6 The staff also performed a limited-scope 7
audit held in August of 2024 related to the biological 8
shield wall. During the review, the Applicant 9
submitted four supplements to the subsequent license 10 renewal application.
11 The staff issued 13 requests for 12 additional information and no second request for 13 additional information during its review.
14 Based on its review of the application, 15 the results of data, and additional information 16 provided by the Applicant, the staff concluded that 17 the Applicant's aging management program activities 18 were consistent with the criteria of the Standard 19 Review Plan for subsequent license renewal application 20 and the requirements of 10 CFR Part 54.
21 We will have the specific areas of the 22 review to discuss.
23 CHAIR KIRCHNER: Marieliz, before you go 24 forward -- sorry to interrupt the flow -- how did you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 go about, for this particular plant, setting up your 1
audit? Was it informed by your Resident Inspector or 2
was it informed by the GALL?
3 Where I'm going with this is you can just 4
go over these AMPS, and we count them all up, and we 5
say they match with or without enhancements, et 6
cetera, et cetera.
7 But when you go actually to the plant and 8
do an audit, what's your strategy and what are you 9
looking for when you go to a plant? Obviously, you've 10 got the entire list, but each plant is different. So, 11 how did you do your audit and what were the major 12 results from the audit?
13 MS. JOHNSON: So, for the audit, for the 14 outside audit, the initial onsite audit, we had two 15 teams. It was mostly the electrical team and the 16 structural team.
17 And the electrical team, they go through 18 the AMPs and they check what they want to see. They 19 also look at the plant's drawings and they decide 20 exactly what things they want to see. They also talk 21 to the Resident Inspector and try to decide exactly 22 what they want to see.
23 For the structural, the same. They go 24 through the AMPs. They go through the drawings and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 choose what they want to see. They went to the dam.
1 They went to see the --
2 CHAIR KIRCHNER: This is V.C. Summer.
3 MS. JOHNSON: Uh-hum.
4 CHAIR KIRCHNER: So, what did you really 5
focus-in on at the audit?
6 MS. JOHNSON: So, for the structural --
7 because we had two PMs for this -- I followed the 8
structurals; the other PM followed the electrical.
9 And for the structurals, I know they went 10 to the dam. They went to the attendant gallery, which 11 is specific for V.C. Summer. And they did go see the 12 overall of the plant. The Applicant told us how 13 there's a crack here, a crack there. So, we went to 14 see those.
15 CHAIR KIRCHNER: So, what did the 16 electrical team really focus on?
17 MS. JOHNSON: Okay.
18 CHAIR KIRCHNER: I'm trying to get let's 19 check the box and here is what we have.
20 MS. JOHNSON: Yes, yes. Matthew McConnell 21 raised his hand. He was there.
22 So, Matthew?
23 MR. McCONNELL: Good morning. This is 24 Matthew McConnell with the Nuclear Regulatory 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 Commission. I'm in the Long Term Operations and 1
Modernization Branch within NRR.
2 When we perform our onsite audits, 3
Marieliz is correct, we look at the AMPs and we have 4
a general idea of what we are looking for.
5 So, when we went to V.C. Summer and prior 6
to going to V.C. Summer, we asked to have a walkdown 7
of various systems and components. We started with 8
the station blackout recovery path, which, basically, 9
went from the switch yard to the plant itself, all the 10 way to, essentially, a switch gear for the diesel 11 generators in 4160.
12 What we're looking for when we're onsite 13 is just the aging mechanisms or any potential 14 degradation that might be abnormal to ensure that 15 their aging management programs are adequately 16 developed to catch and correct any potential 17 degradation mechanisms.
18 Because we have a lot of experience from 19 every plant, you know, we know what we're looking for.
20 V.C. Summer, no different. They did not have much, if 21 at all, any, actually, degradation that we observed 22 for cabling, for overhead connectors, for transmission 23 conductors, and insulators.
24 I hope that answered your question.
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69 CHAIR KIRCHNER: Yes. Thank you.
1 I'm just trying to prevent us glazing over 2
on the number of AMPs with and without modification, 3
et cetera, et cetera, and what you actually are 4
targeting when you do an audit at one of the plants.
5 Thank you.
6 MR. McCONNELL: Yes. If I may add, we 7
also look at manholes and cables within manholes, if 8
they are in scope, to observe/ensure that, if they 9
were subjected to water, they would not have any aging 10 mechanisms observed or identified, and based on 11 testing and inspection frequency.
12 MR. WISE: This is John Wise --
13 CHAIR KIRCHNER: Yes. Get much closer to 14 the microphone.
15 MR. WISE: I'm sorry. I'll be real close 16 here.
17 Hi. John Wise, NRC.
18 I just want to give a little more 19 perspective. I think you're asking some kind of 20 big-picture questions about how we approach an audit, 21 right?
22 And so, when we think about, you know, why 23 do we have an audit, historically, it's been our 24 opportunity to just verify some of the information 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 that's present in the application. That's simply 1
enough. And for those simple programs, that's not a 2
big lift.
3 And then, the opportunity is to look at, 4
dig into the plant's specific operating experience.
5 So, our audits include an operating experience review.
6 And that's where staff get a chance to begin to ask 7
questions of the plant, dig into the details.
8 And also, sometimes plants have, evident 9
in the application, plants have some unique -- maybe 10 there's some unique structures or unique materials.
11 And getting onsite is an opportunity for the staff to 12 explore those further and to really understand if the 13 program that they're proposing, it will be adequately 14 covered.
15 But, going forward, we recognize that this 16 is becoming a mature process, as we discussed earlier.
17 And so, we're looking and we have actually started the 18 process to kind of refine our audits to really focus 19 on the staff that really matters. Some of these 20 programs are pretty mature and we don't want to spend 21 a lot of time unnecessarily, our time and the 22 Applicant's time, asking about some fairly mature 23 programs.
24 And so, we have an approach that we've 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 been highlighting for Dresden and Clinton, ongoing 1
reviews where we actually are asking the staff to kind 2
of pare down and focus the audits for resource 3
savings.
4 CHAIR KIRCHNER: Thank you.
5 MEMBER SUNSERI: Well, I would add, that's 6
much like what the ACRS does for our review. But I 7
would caution, we just don't look -- we just don't 8
accept something as a mature process. We factor in 9
that operating experience extremely high, because even 10 though a program might be mature, there might be some 11 operating experience, a point that we need to be 12 looking at that closely. So, we will. That's kind of 13 how we do our reviews, a similar approach.
14 MEMBER HARRINGTON: This is Member 15 Harrington.
16 Just to follow up on this whole thread, 17 you focused on electrical and structures. Is that 18 because that's where the changes in the GALL have been 19 or is there something else that said these are two 20 areas; we don't need to look at mechanical or 21 something else?
22 MS. JOHNSON: I would say the onsite 23 focused on structural and electrical. The audit, like 24 John said, we focused on everything. But going 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 onsite, it's basically those two that they want to 1
see.
2 MEMBER HARRINGTON: So, that's more 3
typical of these kinds of audits, not just because it 4
was V.C. Summer?
5 MS. JOHNSON: Oh, no. Yes. And if 6
someone from mechanical sees something on another 7
project on a plant that they want to go see, they go 8
to the site. But, for this one, electrical and 9
structural were the ones that requested going on the 10 site. But everyone, all the mechanicals also do the 11 audit electronically.
12 Oh, okay. So, regarding the inspection of 13 the water control structure associated with nuclear 14 power plants, the dams are inspected as part of the 15 NRC dam safety program. These inspections occur every 16 two or three years, and the last inspection report 17 showed the dam to remain in compliance with federal 18 guidelines. The report can be found in ADAMS. The 19 non-proprietary cover letter of the report is 20 ML243448196.
21 VICE CHAIR HALNON: Marieliz, this is 22 Greg.
23 On the inspection, they mentioned that 24 FERC comes in every three years. How's that formally 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 communicated, their finding results, back to the NRC?
1 Is there an MOU or is there some joint effort? How is 2
that communicated?
3 MS. JOHNSON: So, I know there's a report.
4 I don't know if FERC --
5 VICE CHAIR HALNON: It sounds like a 6
friend is trying to help you out.
7 (Laughter.)
8 There you go. Okay, Dan, go ahead.
9 MR. HOANG: Yes. Good morning. This is 10 Dan Hoang with the staff.
11 The FERC has a contract with the NRC 12 because, according to a Code mandate of 1978, the 13 contract went to FERC to do the inspections because 14 FERC does it for a living. And so, therefore, the 15 FERC likes to do the inspection. However, they report 16 to us, that we can turn to their report, and we submit 17 a copy to the licensee. Yes.
18 VICE CHAIR HALNON: Okay. Very good.
19 Thank you, Dan.
20 MR. HOANG: You're welcome.
21 MEMBER BIER: I have another question.
22 This is similar to the question that I asked of the 23 Licensee earlier.
24 Which is, when you do the dam inspection, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
74 do you also inspect the just general surroundings of 1
the pond? Because there can be problems with just 2
earthen structures.
3 MR. HOANG: Yes. Yes, ma'am. We do 4
inspections of the surrounding if it is involved with 5
the structure. Because the inspector and myself, we 6
have a structural engineering degree and, also, we 7
have a PE license. So, we know what we're supposed to 8
do and what we are supposed to have an inspection for 9
and how an adjustment is.
10 MEMBER BIER: Okay. Thank you.
11 MR. HOANG: You're welcome.
12 MS. JOHNSON: Okay. And as a part of the 13 license renewal review, the staff conducted a review 14 of the plant operating experience search results to 15 identify examples of age-related degradation, as 16 documented on the Corrective Action Program database 17 and provide a basis for the staff conclusion on the 18 ability of the Applicant's proposed AMP to manage the 19 effect of aging in the subsequent period of extended 20 operation.
21 The staff did not identify any operating 22 experience indicating that the Applicant should modify 23 its proposed program. Based on its audit and review 24 of the application, the staff finds that the condition 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 and operating experience at the plant are bounded by 1
those for which the inspection of the water control 2
structure associated with the nuclear power structure 3
program was evaluated.
4 Regarding the biological shield wall 5
irradiated concrete and steel, the primary shield 6
wall, or PSW, fluence, neutron fluence, and gamma dose 7
are above the threshold that requires evaluation 8
discussed in the SRP-SLR. So, the Applicant performed 9
for their evaluation.
10 Regarding the inspections of reactor 11 vessel, or RV, supports, the Applicant will perform 12 aging management activities consistent with the GALL 13 SLR Report that include, but are not limited to, ASME 14 Section 11, Subsection IWF, "Structure Monitoring,"
15 and various AMPs to monitor aging effects of reactor 16 vessel supports.
17 Additionally, as the Applicant mentioned, 18 the Applicant has the following ongoing proposed 19 activities:
20 Official inspections of the six RV 21 supports every 10 years, as directed by the In-Service 22 Inspection, or ISI, program.
23 Further enhance with additional 24 inspections of at least one support every five years.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 Review of the RV supports inspection 1
results under the Structural Monitoring Program for 2
conditions that may require evaluation of the primary 3
shield wall, concrete, and grout.
4 Inspection of the in core feed room under 5
the RV twice per refueling RS. If evidence of 6
degradation, such as debris, is noted, a Condition 7
Report is initiated in the Corrective Action Program 8
for evaluation.
9 And monitoring of the condition of the 10 outside of the PSW concrete every five years under the 11 Structural Monitoring Program.
12 The NRC review of the ancillary FSAR 13 drawings and documents available during audit. The 14 staff also performed a limited-scope audit and onsite 15 audit and documented their observations in the 16 associated audit report, ML250078234.
17 Following the
- audit, the Applicant 18 supplemented their application to identify the needed 19 activities to advance the further evaluation of the 20 primary shield wall concrete and reactor vessel steel 21 supports.
22 At this time, do you have any questions on 23 this?
24 MEMBER SUNSERI: No questions.
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77 MS. JOHNSON: No questions? Excellent.
1 At this time, I will turn it to over Steve 2
Downey, Reactor Inspector from Region II, who will be 3
discussing inspections and plant material conditions.
4 MR. DOWNEY: Yes, good morning, Chairman 5
and Committee.
6 I can't hear myself.
7 MS. JOHNSON: I think it is okay. Get 8
close to the mic.
9 MR. DOWNEY: Okay. My name is Steve 10 Downey, as mentioned earlier. I'm the Senior Reactor 11 Inspector out of NRC Region II, Division of Operating 12 Reactor Safety, Engineering Branch III. I'm one of 13 the license renewal points of contact for Region II, 14 and I was the team lead for the phase 2 inspection at 15 V.C. Summer.
16 With me is Mac Reed, Senior Resident at 17 V.C. Summer, and we are here to discuss Region II's 18 assessment and review of the implementation of aging 19 management programs, the material condition of the 20 plant, and the overall regulatory assessment of V.C.
21 Summer Unit 1.
22 MEMBER SUNSERI: Yes, let me just 23 interrupt you. Just move that stanchion right in 24 front of you, the microphone, and make sure it's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 pointed right at you.
1 You have some important information for 2
us. We always like to hear from you and we want to 3
make sure we hear you clearly.
4 MR. DOWNEY: All right. Just let me know 5
if my sound isn't good for you.
6 MEMBER SUNSERI: Just use your outside 7
voice.
8 (Laughter.)
9 MR. DOWNEY: That's easy enough to do.
10 So, the license renewal inspection program 11 and the ROP baseline inspection program are both used 12 to inspect aging management activities at V.C. Summer.
13 I'll start with the activities under the license 14 renewal inspection program, and then, we'll discuss 15 the ROP inspections, and Mac will follow up with the 16 material condition of the plant.
17 So, in order to assess the adequacy of the 18 license renewal program for the initial period of 19 extended operation, Inspection Procedure 71003 20 recommends a four-phased approach to license renewal 21 inspections.
22 This slide details the specific license 23 renewal inspections that have been or will be 24 performed at V.C. Summer. As I discuss each line 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 item, I will give a bit of detail on what the 1
inspection entails or will entail when it's performed.
2 So, the phase 1 inspection, which we 3
performed at Unit 1 in October 2021, which was during 4
refueling outage 26, which is the last outage prior to 5
going into the period of extended operation, this is 6
an outage inspection that focuses on observing the 7
implementation of select aging management programs and 8
activities, as well as any testing or visual 9
inspections of structures, systems, and components 10 which are only accessible at reduced power levels.
11 During the outage, we performed the phase 12 1 license renewal inspection, per Inspection Procedure 13 71003, as well as the baseline ISI inspection, per 14 Inspection Procedure 71111.08.
This allowed 15 inspectors to maximize the observation of activities 16 credited for license
- renewal, which includes 17 examinations performed as part of the In-Service 18 Inspection Program, the Buried Piping and Tanks 19 Program, and the Chemistry Program, as well as 20 one-time inspections performed on small-bore ASME --
21 ASME is American Society of Mechanical Engineers --
22 Class 1 piping.
23 So, no findings of significance were 24 identified as a result of the phase 1 inspection or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 the baseline ISI inspection.
1 Next --
2 MEMBER SUNSERI: I can't help but notice 3
your graphic says, "Unit 1 and Unit 2." Are you still 4
pursuing other units?
5 MR. DOWNEY: I'm sorry, that is a typo.
6 MEMBER SUNSERI: Oh, okay. All right.
7 MR. DOWNEY: I apologize for that.
8 So, the phase 2 inspection, which we 9
performed in February 2022, is a one-time major team 10 inspection during which the inspectors evaluate the 11 license renewal program prior to the period of 12 extended operation by taking a comprehensive look at 13 the implementation and/or completion of regulatory 14 commitments, aging management programs, time-limited 15 aging analyses, and other activities associated with 16 the licensee's request to renew its operating license.
17 So, there were a total of 41 regulatory 18 commitments linked to the renewed operating license, 19 the initial operating license from V.C. Summer, two of 20 which were resolved during the licensing review and 21 not subject to further inspection, and the remaining 22 39 commitments were included in my sample for the 23 phase 2 inspection and are categorized as follows:
24 There were 17 commitments to implement new 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
81 aging management programs; eight commitments to 1
enhance existing aging management programs for license 2
renewal; two commitments to perform a one-time 3
inspection of structures, systems, or components 4
within the scope of an existing aging management 5
program; six commitments to perform time-limited aging 6
analyses, and six standalone commitments. And I refer 7
to them as "standalone" because they're not associated 8
with an individual aging management program or 9
time-limited aging analysis.
10 So, during the inspection, the team 11 determined that the actions associated with 37 of the 12 39 regulatory commitments were completed. For those 13 license renewal action items that were not completed 14 at the time of the inspection, the team verified that 15 there was reasonable assurance that such action items 16 were on track for completion prior to the period of 17 extended operation or in accordance with an 18 established implementation schedule consistent with 19 the licensing basis.
20 During the inspection, the team also 21 verified that the licensee had taken appropriate 22 action related to newly identified structures, 23 systems, and components, as required by 10 CFR 24 54.37(b); that the appropriate processes were in place 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 for evaluating, reporting, and seeking approval for 1
commitment changes, and that the descriptions of the 2
aging management programs in the Final Safety Analysis 3
Report were consistent with what the agency had 4
approved.
5 As a result of the phase 2 inspection, no 6
findings of significance were identified. I can 7
provide the latest information on the two commitments 8
that were not completed at the time of the inspection, 9
if the Committee wishes to hear more. And that's a 10 question for you all, if you want to hear about those.
11 MEMBER SUNSERI: Members?
12 (No response.)
13 MR. DOWNEY: Okay. In that case, I'll 14 move on to an inspection that not mentioned on this 15 slide here, which is the phase 3 inspection, because 16 we did not perform a phase 3 inspection at V.C.
17 Summer. But the phase 3 is a followup inspection that 18 will be performed to address outstanding issues, if 19 any, that were identified during the phase 1 or phase 20 2 inspections.
21 And finally, the phase 4 inspection, which 22 typically occurs 5 to 10 years into the period of 23 extended operation, is yet to be performed at V.C.
24 Summer. As we all know, the site entered the PEO in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 August of 2022. So, we would expect the phase 4 1
inspection to be performed somewhere in the range of 2
2027 to 2032. When performed, this inspection will 3
verify that the licensee is managing the aging effects 4
in accordance with their aging management programs, as 5
described in their Final Safety Analysis Report.
6 I'll also note here that, if V.C. Summer 7
is approved for a subsequent license, then the NRC 8
inspection program will include additional phases 9
designated as phase 5 and phase 6. And the phase 5 10 inspection is similar to the phases 1 and 2, in that 11 it's an inspection that would occur prior to the 12 subsequent period of extended operation; whereas, the 13 phase 6 inspection is similar to a phase 4 inspection.
14 That's an implementation of an aging management 15 program effectiveness inspection that would occur 5 to 16 10 years into the subsequent period of extended 17 operation.
18 Next slide, please.
19 So, in addition to the inspections 20 mandated by license renewal, by the license renewal 21 inspection program, the inspectors have several ROP --
22 that's reactor oversight process baseline 23 inspections that could be used to evaluate the 24 implementation of aging management activities.
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84 For example, the baseline ISI inspection, 1
which is performed at every outage, gives the 2
inspectors the opportunity to look at inspections 3
credited for aging management that are within the 4
scope of various programs.
5 Another example is the heat sink 6
inspection, which gives inspectors the opportunity to 7
look at the service water system, including heat 8
exchangers, the service water intake structure, and 9
both aboveground and buried or inaccessible piping and 10 components, all of which are within the scope of 11 license renewal.
12 I will note here that, in 2024, the 13 triennial component of the heat sink inspection, which 14 was performed by the Region-based engineering 15 inspectors, was folded into what we now call the 16 Comprehensive Engineering Team Inspection, which I'll 17 refer to a couple of times as the CETI, while the 18 annual heat sink inspection is still performed by the 19 Resident Inspectors.
20 So next, the CETI, or Comprehensive 21 Engineering Team Inspection, and the Fire Protection 22 Triennial Inspection Procedures, both direct the 23 inspectors to ensure that structures, systems, and 24 components selected in the inspection sample that are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 subject to aging management review are being managed 1
in accordance with appropriating aging management 2
programs.
3 At V.C. Summer, the Regional Inspectors 4
have found no violations or findings of significance 5
as a result of the inspections performed under this 6
procedures.
7 Additionally, the Resident Inspectors at 8
Summer have performed a variety of inspections, 9
including maintenance effectiveness and problem 10 identification and resolution inspections, or PIR, on 11 samples that focused directly or indirectly on 12 associated aging management programs.
13 VICE CHAIR HALNON: Steve, this is Greg.
14 I just wanted to do a numbers check.
15 MR. DOWNEY: Sure.
16 VICE CHAIR HALNON: In 2022, we had an 17 erratic diesel generator governor suffer failure. In 18 2023, we had another diesel generator problem, another 19 self-revealing problem on the main feedwater pump for 20 a thrust bearing issue. In 2024, we had a 21 self-revealing finding on P&T that failed on a chiller 22 because of a design deficiency. Yet, you said no 23 violations or findings were found in these.
24 So, help me with those numbers there.
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86 MR. DOWNEY: Yes. So, the no findings or 1
violations are for the Region-based inspections, which 2
would include the ISI inspection, the heat sink 3
inspection, triennial fire protection, and the CETI 4
inspection.
5 The issues that you're mentioning would 6
fall under the umbrella of the problem identification 7
and resolution. The Residents are the focal point of 8
those inspections. So, we can --
9 VICE CHAIR HALNON: So, Mac, you don't 10 have to answer now because you're going to have a 11 slide later on. Help me with your confidence in the 12 Corrective Action Program when you get to the diesel 13 generator discussion that you're going to have.
14 MR. REED: Got you.
15 MR. DOWNEY: So, then, that's a perfect 16 segue, because I was going to mention the notable 17 inspection result of the white finding of the diesel, 18 which the licensee discussed a bit earlier and we'll 19 discuss more on the upcoming slide.
20 Next slide, please.
21 So, at this point, I'll turn it over to 22 Mac Reed to discuss the material condition of the 23 plant and the Resident Inspector viewpoint.
24 MR. REED: Yes, Mac Reed, Senior Resident 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 Inspector at V.C. Summer. I've been there for about 1
five years.
2 And thank you for reading the Inspection 3
Reports.
4 (Laughter.)
5 I should say I look forward to answering 6
any of your specific questions about that, as well as 7
the programs at V.C. Summer.
8 So, specifically, I'm here to speak about 9
the material condition of Summer from the Resident 10 Inspector viewpoint. Again, for everybody, we are 11 there daily. We observe the plant. We do about 150 12 targeted inspections every year and we do write 13 occasionally some violations that I would be glad to 14 speak about more, anything that you have in your mind.
15 So, V.C. Summer Unit 1 is in the "Licensee 16 Response" column of the reactor oversight process.
17 And I did note in this script that there were many 18 diesel generator failures since I've been here the 19 last five years.
20 The one specific one, I'll try to 21 streamline that conversation, since Dominion already 22 presented on the fuel oil piping, but there were other 23 issues with the diesel generators not associated with 24 the fuel piping.
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88 Here's the slide. So, just to streamline 1
this and give you a high-level summary, you heard the 2
details from Dominion. Everything they said about the 3
corrective actions was correct.
4 We identified that over the years 5
maintenance activities had identified cracked threads, 6
but they had not been adequately documented in the 7
Corrective Action Program such that they could be 8
trended and a global, more comprehensive corrective 9
action could be established.
10 And as a
- result, the system 11 vulnerabilities eventually resulted in a surveillance 12 test failure during a 24-hour performance test. And 13 essentially, they sprayed fuel oil everywhere and they 14 had to shut down the diesel.
15 I want to focus on the Corrective Action 16 Program because that was ultimately the apparent 17 violation -- a failure to adequately document and 18 assess previous issues.
19 So, all these issues that were identified 20 were under the SCE&G umbrella prior to my time at V.C.
21 Summer.
22 One of the things that I want to note 23 about the Corrective Action Program through the root 24 cause analyses that they performed for this issue, as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
89 well as the Amphenol connection issue with the 1
kilowatt swings that you read about, the Corrective 2
Action Program at V.C. Summer in the last five years 3
has improved dramatically.
4 The critical thing for me, and the thing 5
that we sort of take for granted in what we assume in 6
all of our aging management reviews, license renewal 7
reviews, is that things will be documented in the 8
Corrective Action Program. So, that's the "I" in PI&R 9
for problem identification and resolution. So, the 10 Resident Inspectors are there to ensure that things 11 are documented in a very low threshold, and that has 12 greatly improved.
13 Hopefully, that answers or at least 14 initially answers your question.
15 MEMBER BIER: If I can follow up, on root 16 cause analysis, people talk about extent of cause and 17 extent of condition. In other words, if you find a 18 problem with the diesel generators, is that only 19 because of something with the diesels or is there a 20 broader issue that might affect other SSCs, or 21 whatever, based on what you observe?
22 And can you talk about how far you broaden 23 out from the observations to look at other possible 24 issues?
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90 MR. REED: Yes, ma'am.
1 So, specifically talking about the fuel 2
oil line rupture --
3 MEMBER BIER: Yes.
4 MR. REED: -- the licensee did do an 5
extended condition on safety-related items. They 6
expanded the scope to threaded connections throughout 7
the plant, Schedule 40 piping, to determine if they 8
had any other weaknesses where they had leaks that 9
were not adequately evaluated or they did need 10 uprating.
11 The key, in my perspective, was the 12 vibrations that you all brought up earlier. The 13 vibrations significantly contributed to the wear. And 14 if you put a moment or a torque on Schedule 40 15 threaded connections and you vibrate it, it will 16 eventually fail.
17 MEMBER BIER: Uh-hum.
18 MR. REED: So, they have remediated 19 through modifications of both of their emergency 20 diesel generators and they have performed an adequate 21 extended condition on other safety-related components 22 that use threaded connections. I don't think there's 23 any other components that vibrate as heavily --
24 MEMBER BIER: Yes.
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91 MR. REED: -- as the region that failed.
1 MEMBER BIER: Okay. Thank you.
2 MEMBER SUNSERI: Was there any industry 3
operating experience shared on that issue? Because 4
that's a configuration issue. There's other places.
5 MR. REED: Yes. So, INPO has an IRIS 6
database that requires all equipment failures to be 7
documented. So, the root cause evaluation and for 8
other failures that you all mentioned, the 9
self-revealing failures, those would have what we call 10 level-of-effort evaluations, which is just a lower 11 tier of cause evaluation. Those are put into the 12 industry's INPO database, and some of our NRC folks 13 have access to that in our OPI Branch. They can 14 review those. And the expectation is that other 15 utilities would be using that information to inform 16 their definitive maintenance programs.
17 MEMBER SUNSERI: Thank you.
18 MR. REED: All right. So, let's skip the 19 rest, unless you have any more questions about this 20 specific diesel failure.
21 Go to the next slide.
22 VICE CHAIR HALNON: Yes, not specific to 23 this, but, as someone familiar with the culture on the 24 site, tell me if you agree. It's a high level of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
92 ownership if the systems. I think some of the 1
engineers would take the components home with them, if 2
they could, to make sure they stayed (audio 3
interference). There's a great desire to be the best 4
in what they do.
5 Did you see that promulgating through this 6
Corrective Action Program? Since the answer is so 7
dependent on a strong Corrective Action Program, do 8
you see that culture of ownership and desire to be 9
excellent going through into this new Corrective 10 Action Program? I'm calling it "new," but it's, you 11 know, Dominion's existing.
12 MR.
REED:
They did revise their 13 Corrective Action Program when Dominion bought SCE&G.
14 A lot of the procedures were changed.
15 But, specifically to the Corrective Action 16 Program, really the criteria did not change. The 17 changes were the leadership from the site engaging 18 with the Residents when we had perspectives on the 19 threshold that they were putting things into the 20 Corrective Action Program.
21 And with the significant improvements 22 following the two white findings, as well as other 23 issues that we brought to them, they have driven a 24 cultural change at V.C. Summer to identify things in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
93 the Corrective Action Program at a very, very low 1
threshold.
2 And so, what we were seeing, for example, 3
to give you some perspective, the maintenance 4
organization is very strong at V.C. Summer. They 5
routinely go into components and they assess the 6
condition.
7 Some examples where they were going into 8
these components and finding less-than-expected 9
conditions, and they were writing it in the work 10 orders and the closure notes, but those don't 11 propagate up to the management team for review or into 12 the Corrective Action Program for trending.
13 So, the knowledge that they provide when 14 they take apart these systems was not being translated 15 into the Corrective Action Program at the right 16 threshold. And when things were broken or a test 17 failed, those absolutely went into the Corrective 18 Action Program and that was always there. The 19 leadership team drove a
lower threshold for 20 identification.
21 Excellent example. It sounds like they've really 22 embraced the new culture then.
23 MR. REED: Uh-hum.
24 VICE CHAIR HALNON: Thanks.
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94 MEMBER SUNSERI: Does that documentation 1
of "as found," if you will, cascade into the 2
preventive maintenance programs, too, for adjusting 3
frequencies of AMPs for safety?
4 MR. REED: Yes, and that has changed 5
slightly over the years. But if it's less than 6
expected and it's documented, then that would be 7
evaluated for adjustments to the frequency.
8 MEMBER SUNSERI: And for the corrective --
9 MR. REED: Yes, sir.
10 MEMBER SUNSERI: thank you.
11 MR. REED: All right. Next slide.
12 Overall, for a plant that's in its first 13 period of extended operation, the material condition 14 is generally acceptable. The licensee has been 15 successful at completing large capital improvement 16 projects that maintain or improve the material 17 condition of its SSCs -- structures, systems, and 18 components.
19 Furthermore, the NRC white and green 20 findings have not only been corrected, but the 21 licensee has improved their corrective action and 22 preventative maintenance programs to correct the 23 cause.
24 Finally, the license renewal program 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 inspections did not identify any substantial 1
weaknesses in the station's performance in managing 2
the effects of aging onsite.
3 Going forward, the agency will continue to 4
inspect and assess the licensee's ability to manage 5
the effective aging through our baseline inspection 6
and license renewal inspection programs. In this 7
manner, our oversight will continue to provide us with 8
insights into the effectiveness of the various aging 9
management programs in place at V.C. Summer.
10 Now, I'll answer any more questions, and 11 then, turn it back over to Marieliz.
12 CHAIR KIRCHNER: Let me put you on the 13 spot. So, what's the condition of the plant?
14 (Laughter.)
15 MR. REED: It's generally in a very good 16 condition. Housekeeping is really strong. There are 17 probably areas that could be improved. Because if you 18 don't -- some of the aging management programs we talk 19 about require you to go look. It may not be obvious 20 from a routine walkdown.
21 So, I can't speak to the things that we 22 can't see. The things I can see are in generally good 23 condition.
24 And you've read some of the self-revealed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
96 issues that we've written up, and we've reviewed every 1
major equipment failure to ensure that the causes are 2
being corrected.
3 CHAIR KIRCHNER: And at the last outage, 4
in containment, what was your assessment of the 5
triple-S system?
6 MR. REED: Containment is in a pretty good 7
condition. I think Dr. Downey has also toured V.C.
8 Summer several times. So, I've had the opportunity to 9
-- again, there may be two dozen times in my time at 10 V.C. Summer.
11 The material condition is good. The 12 coatings on the steel, especially some piping, have 13 really degraded over time. And they do have plans to 14 replace coatings, especially on critical components, 15 critical piping sections.
16 For instance, the reactor building cooling 17 unit, cooling last year, they underwent a campaign to 18 scrape off degraded coatings and reapply.
19 CHAIR KIRCHNER: Thank you.
20 MEMBER SUNSERI: Members?
21 (No response.)
22 MS. JOHNSON: Okay. So, thank you.
23 In conclusion, for the subsequent license 24 renewal application safety review, the staff finds 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 that the requirements of 10 CFR Part 54.29(a) have 1
been met for the subsequent license renewal for V.C.
2 Summer Unit 1.
3 And this concludes our presentations. So, 4
if you have any other questions, we will be happy to 5
respond.
6 MEMBER SUNSERI: All right. Well, thank 7
you for the thorough presentations. We appreciate 8
your perspectives on things. That adds to our 9
deliberations.
10 At this point, I would like to dismiss the 11 staff and invite the public for comments.
12 CHAIR KIRCHNER: So, Members of the 13 Public, if you have a comment, unmute yourself, 14 identify yourself, affiliation as appropriate, and 15 make your comment.
16 Anyone in the room?
17 (No response.)
18 MEMBER SUNSERI: Okay. Well, I guess that 19 concludes our review of --
20 MS. GREENLAW: I'm sorry, I was just able 21 to unmute myself. I couldn't find the unmute button.
22 MEMBER SUNSERI: Well, okay. Go ahead 23 then. Please state your name and your affiliation and 24 provide your comments.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 MS. GREENLAW: Okay. My name is Pamela 1
Greenlaw. I am a nuclear power user. Okay.
2 I have a question. It's not related to 3
technical. So, I'm wondering if I should save it for 4
a different portion of this program today. But I will 5
go ahead and pose it now.
6 I'm wondering why there are public 7
hearings for the EIS and not the Safety Report.
8 Thank you.
9 MEMBER SUNSERI: Well, thank you for the 10 comment.
11 We are not this is not a
12 question-and-answer session, but we have recorded the 13 question, and if you want to contact Kent Howard of 14 our staff, he's the Designated Federal Official and he 15 will provide our response.
16 MS. GREENLAW: Okay. I'm not familiar 17 with this person. Their contact information is too 18 difficult to find elsewhere. So, I came today.
19 MEMBER SUNSERI: It should be in the 20 meeting announcement. Oh, here, yes, it's right here.
21 Just look on the meeting announcement, Kent Howard.
22 MS. GREENLAW: Howard?
23 MEMBER SUNSERI: Yes. He's the Designated 24 Federal Official.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
99 MS. GREENLAW: Okay. I just saw two other 1
names in the announcement.
2 You don't have a chat feature, do you, 3
that you could put that in? Yes, you do.
4 CHAIR KIRCHNER: Let's just quickly give 5
it to you here in real time.
6 MS. GREENLAW: Thank you.
7 CHAIR KIRCHNER: Kent, K-E-N-T, period, 8
Howard, H-O-W-A-R-D, @nrc.gov.
9 MS. GREENLAW: "K" as in kitten, E-N-T, as 10 in Tom?
11 CHAIR KIRCHNER: Yes, period, then, 12 Howard.
13 MS. GREENLAW: Thank you very much.
14 Howard@nrc? All right.
15 CHAIR KIRCHNER: Dot gov.
16 MS. GREENLAW: Dot gov. I've got it.
17 Thank you very much.
18 CHAIR KIRCHNER: Thank you for your 19 comment.
20 MS. GREENLAW: Thank you.
21 MEMBER SUNSERI: Any other comments?
22 CHAIR KIRCHNER: Any other comments from 23 the public?
24 (No response.)
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 MEMBER SUNSERI: Okay. So, continuing on 1
then, Chairman, I suggest that we will take a recess 2
at this point in time and come back at your 3
discretion.
4 But we have a Draft Letter Report that the 5
Subcommittee has prepared. I will request to read 6
that into the record, and then, go into deliberation 7
on that report. There are a few changes to the draft, 8
I noted, as a result of the staff and Applicant 9
presentation, but we can catch those during 10 line-by-line review, I believe.
11 CHAIR KIRCHNER: Great. So, at this 12 point, we are going to recess for 15 minutes and come 13 back and read the Draft Letter Report into the record 14 when we resume at -- I've lost the indication of the 15 time.
16 MEMBER SUNSERI: It's 10:32.
17 CHAIR KIRCHNER: It's 10:32 right now.
18 Let's resume at 10:45.
19 (Whereupon, at 10:32 a.m., the open 20 meeting was adjourned, and after a brief recess, 21 resumed in closed session for Committee deliberation.)
22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
V. C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 SUBSEQUENT LICENSE RENEWAL APPLICATION ACRS Committee Meeting March 6, 2025 March 6, 2025 1
Agenda March 6, 2025 2
- Introductions
- V.C. Summer Site Overview
- Technical Topics
- Closing Remarks
Introductions
March 6, 2025 3
Beth Jenkins, VCSNS Site Vice President James Holloway, Vice President Nuclear Engineering & Fleet Support Brenda Brown, Director - Nuclear Engineering - VCSNS Calvin Pugh, SLR Director Richard Burtt, Manager - Nuclear Site Engineering - VCSNS Keith Miller, SLR Supervisor Chuck Tomes, SLR Technical Lead Pratt Cherry, SLR Mechanical Lead
Site Layout March 6, 2025 4
V.C. Summer Overview March 6, 2025 5
Station Milestones Year Initial License (2775 MWt) 1982 4.5% Uprate Approved (2900 MWt) 1996 Renewed License Issued 2004 Entered Period of Extended Operation 2022 Current License Expiration 2042
V.C. Summer Overview March 6, 2025 6
- Westinghouse 3-loop PWR
- Refueling frequency - 18 months
- Regulatory Status
- Reactor Oversight Process Actions Matrix Column 1
- All ROP indicators are Green
- Recent capacity factors:
Year Capacity Factor 2020 91.07 2021 82.69 2022 101.52 2023 88.82 2024 87.46
V.C. Summer Overview March 6, 2025 7
Significant Plant Upgrades Since Initial License Renewal Fire Protection Piping & Valve Replacement Campaign Service Water Chemical Treatment Optimization Emergency Feedwater/Service Water Cured-In-Place-Pipe Liner Installation Main Transformer Replacement Electro-Hydraulic Control Digital Installation Service Water Cavitation Mitigation EDG Fuel Oil Piping Upgrade Safety-Related Chiller Replacements
Subsequent License Renewal Application March 6, 2025 8
- Project Team Experience
- V.C. Summer SLR is the 3rd Dominion SLR project performed by this team
- Team also has experience from SLR projects with other utilities and initial license renewal projects
- Industry Involvement
- Participant in peer reviews of other SLRAs
- Active participant in the NEI License Renewal Task Force
Subsequent License Renewal Application March 6, 2025 9
- Regulatory and Industry Guidance
- Focused on consistency with NUREG-2191, NUREG-2192, NRC Interim Staff Guidance, and NEI 17-01
- Benchmarking
- Recent SLR applications and correspondence (e.g.,
Supplements, RAIs) reviewed for insights
- Built on Surry and North Anna SLR experience (e.g.,
leveraged Fleet programs, incorporated lessons learned from NRC reviews)
- Conducted a peer review of our SLRA
Subsequent License Renewal Application March 6, 2025 10 Aging Management Reviews
- High AMR consistency for SLR (>99% of AMR items use Notes A through E)
Operating Experience
- 10 years of station operating experience reviewed for aging-related insights
- License renewal self-assessment performed in 2021
- NRC IP 71003 inspection identified no findings or violations (2022)
Aging Management Programs
- 49 programs for SLR
Subsequent License Renewal Application March 6, 2025 11 AMP Category AMPs Consistent with GALL AMPs Consistent with Enhancement AMPs with Exceptions AMPs with Exceptions and Enhancements Plant Specific AMPs Existing 40 13 22 2
3 0
New 9 9
0 0
0 0
Total 49
Technical Topics March 6, 2025 12 Service Water Pond EDG Performance Primary Shield Wall & Reactor Vessel Supports
Service Water Pond March 6, 2025 13
March 6, 2025 14 Service Water Pond Aging Management Dams and embankments inspected for erosion, movement, surface cracks, sloughing, rip-rap failures, weed and brush control, animal burrows, etc - annually Dam elevation, alignment, and slope surveys are conducted -
every 5 years Sedimentation - bottom elevation surveys (two) were conducted - enhancement to conduct on periodic basis Federal Energy Regulatory Commission dam inspection -
every 3 years
EDG Performance March 6, 2025 15
- VCSNS received a White performance deficiency identified when the licensee failed to identify and correct a condition adverse to quality for the Emergency Diesel Generator (EDG) fuel oil system that left the system vulnerable to piping cracks and eventually resulted in the failure of the A EDG during testing on November 2, 2022.
- The direct cause was a circumferential crack formed at the root of the last engaged male fuel oil pipe nipple thread. The crack propagated through-wall 140 degrees during a 24-hour surveillance run.
- VCSNS completed a Root Cause Evaluation (RCE) to further understand the organizational, process, and material aspects of the event.
EDG Performance March 6, 2025 16
- Replaced threaded schedule 40 piping with schedule 80, mostly welded joints, flexible hoses and flanged connection.
- Additionally, corrective actions from the RCE were completed to correct organization, equipment, and process issues identified.
- Corrective Action Program and Plant Health process changes, and the Prevention Culture Model implementation
- All monthly and periodic EDG surveillance runs since the piping modification have been performed satisfactorily.
EDG Performance March 6, 2025 17 Piping Arrangement - Then Piping Arrangement - Now
Technical Topics Primary Shield Wall & RV Supports March 6, 2025 18
V.C. Summer SLR Summary March 6, 2025 19
- Dominion has a produced a quality SLR application that has a high degree of consistency with GALL-SLR, and incorporates lessons learned from previous SLRAs
- The V.C. Summer SLRA was developed by the very experienced team that wrote the Surry and North Anna SLRAs
- Dominion Energy will continue to invest in people, program enhancements, and equipment modifications through the SPEO
Advisory Committee on Reactor Safeguards Virgil C. Summer Nuclear Station, Unit 1 Subsequent License Renewal Application (SLRA)
Safety Evaluation (SE)
March 6, 2025 Marieliz Johnson, Project Manager Steve Downey, Reactor Inspector
Presentation Outline
- Virgil C. Summer Nuclear Station (VC Summer), Unit 1 Licensing History
- VC Summer Aging Management Programs (AMPs)
- Specific Technical Areas of Review
- Inspections and Material Condition of the plant
VC Summer, Unit 1:
Licensing History Unit Initial License Initial License Renewal Application Renewed License Expiration Date 1
11/12/1982 8/6/2002 4/23/2004 8/6/2042 Initial License Renewal Subsequent License Renewal Application Submitted 8/17/2023 Acceptance Determination 10/16/2023 Safety Evaluation 1/21/2025 3
VC Summer, Unit 1 Aging Management Programs SLRA - Original Disposition of AMPs o 49 AMPs in total o 40 existing programs
- 14 consistent with GALL-SLR
- 26 consistent with enhancements and/or exceptions o
9 new programs All consistent SE - Final Disposition of AMPs o 49 AMPs in total o 40 existing programs
- 13 consistent with GALL-SLR
- 27 consistent with enhancements and/or exceptions o
9 new programs All consistent 4
Specific Areas of SLRA Review
- Inspection of Water - Control Structures Associated with Nuclear Power Plants AMP
- Biological Shield Wall - Irradiated Concrete and Steel
- primary shield wall fluence levels
- inspections of reactor vessel supports 5
Region II AMP Inspections 6
License Renewal Inspection Program for Initial Period of Extended Operations Inspection Dates Results U1 & U2 IP 71003 Phase 1 October 11 - November 5, 2021 ML22026A345 No Findings Unit 1 IP 71003 Phase 2 January 31 - February 18, 2022 ML22069B079 No Findings Unit 1 IP 71003 Phase 4 Expected 2027 - 2032 NA
Region II: AMP Inspections 7
ROP Baseline Inspections Inspection Date Aging Management Program IP71111.08 ISI Each outage Boric Acid Corrosion Surveillance Bottom Mounted Instrumentation Inspection Containment ISI Program - IWE/IWL In-Service Inspection Plan Reactor Vessel Internals Inspection Steam Generator Management Program IP71111.07 Heat Sink Annually Triennial:
3Q 2022 Heat Exchanger Inspections Service Water System Reliability and In-Service Testing Program IP 71111.21N.05 Fire Protection Triennial (FPTI) 3Q 2022 Ensure that selected SSCs are being managed for aging in accordance with the appropriate aging management programs IP71111.21M Comprehensive Engineering Team Inspection (CETI) 2Q 2024 Ensure that selected SSCs are being managed for aging in accordance with the appropriate aging management programs IP71111.12 Maintenance Effectiveness 7-8 samples per year Maintenance Rule Structural Monitoring Program Service Water System Reliability and In-service Testing Program Inspections for Mechanical Components IP71152 Problem Identification and Resolution (PI&R) 6-10 samples per year Any applicable AMP based on conditions identified in the licensees Corrective Action Program
No findings from License Renewal Program inspections 2023: White self-revealed finding related to the Emergency Diesel Generator (EDG) fuel oil system that left the system vulnerable to piping cracks and eventually resulted in the failure of the A EDG during testing.
8 Resident Inspector Insight and Inspection Results Region II AMP Inspections
On the basis of its review of the SLRA, the staff determined that the requirements of 10 CFR 54.29(a) have been met for the subsequent license renewal of VC Summer, Unit 1.
SLRA Review Conclusion 9