ML25248A244
| ML25248A244 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/05/2025 |
| From: | James Holloway Dominion Energy South Carolina |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 25-045B | |
| Download: ML25248A244 (1) | |
Text
Dominion Energy South Carolina, Inc.
5000 Dominion Blvd.
Glen Allen, VA 23060 DominionEnergy.com U. S. Nuclear Regulatory Commission Serial No.
25-045B Attention: Document Control Desk NRA/AF:
R1 Washington, DC 20555 Docket No.
50-395 License No.
NPF-12 DOMINION ENERGY SOUTH CAROLINA, INC.
VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION PROPOSED REVISION TO ADMINISTRATIVE CONTROL TECHNICAL SPECIFICATION FOR CONTAINMENT LEAKAGE RATE TESTING PROGRAM By letter dated March 20, 2025 (Serial No.25-045) [ADAMS Accession No. ML25079A198], Dominion Energy South Carolina, Inc. (DESC), submitted a License Amendment Request (LAR) to revise Technical Specification (TS) 6.8.4.g, "Containment Leakage Rate Testing Program," to adopt NEI 94-01, Revision 3-A and the NRC conditions in Revision 2-A. The LAR requests approval to extend the Type C local leak rate test (LLRT) surveillance interval from 60 to 75 months on a performance-based basis, in accordance with 10 CFR Part 50, Appendix J, Option B.
By email dated July 30, 2025, from Mr. Ed Miller (NRC Project Manager) to Mr. Allen Fulmer (Dominion Energy Nuclear Regulatory Affairs) [ADAMS Accession No. ML25211A229], the NRC technical staff identified four areas requiring additional information (3 Requests for Additional Information (RAIs) and 1 Request for Confirmation of Information (RCI)) to facilitate their review of the proposed LAR. DESC agreed to respond by September 5, 2025. The NRC¶s request and DESC¶s response are provided in the attachment to this letter.
Additionally, editorial errors were identified in Section 3.3 of the LAR that require correction. The original LAR 25-045, Section 3.3, stated (errors in BOLD) ³0.6 La equals 176,832 standard cubic centimeters per hour (sccm) and La equals 294,705 sccm.'
This letter supplements LAR 25-045, Section 3.3, to state (corrections in BOLD) ³In accordance with Technical Specification 6.8.4.g, the allowable maximum containment leakage rate (La) pathway total Types B and C leakage is 0.6 La where 0.6 La equals 176,823 standard cubic centimeters per minute (sccm) and La equals 294,705 sccm.'
Should you have any questions regarding this response or require additional information, please contact Mr. Allen Fulmer at (804) 273-2268.
Serial No. 25-045B Docket No. 50-395 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct.
Executed on ___________.
Respectfully, James E. Holloway Vice President +/- Nuclear Engineering and Fleet Support
Attachment:
Response to NRC Request for Additional Information, Proposed Revision to Administrative Control Technical Specification for Containment Leakage Rate Testing Program
Serial No. 25-045B Docket No. 50-395 Page 3 of 3 cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 Mr. G. Edward Miller NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 09 E-3 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector V. C. Summer Nuclear Station Director, Radiation Protection Program Bureau of Land and Waste Management 2600 Bull Street Columbia, SC 29201 Mr. G. J. Lindamood Santee Cooper +/- Nuclear Coordinator 1 Riverwood Drive Moncks Corner, SC 29461
Serial No. 25-045B Docket No. 50-395 Attachment RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION, PROPOSED REVISION TO ADMINISTRATIVE CONTROL TECHNICAL SPECIFICATION FOR CONTAINMENT LEAKAGE RATE TESTING PROGRAM Dominion Energy South Carolina, Inc.
Virgil C. Summer Nuclear Station Unit 1
Serial No. 25-045B Docket No. 50-395 Attachment, Page 1 of 14 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION PROPOSED REVISION TO ADMINISTRATIVE CONTROL TECHNICAL SPECIFICATION FOR CONTAINMENT LEAKAGE RATE TESTING PROGRAM By letter dated March 20, 2025 (Serial No.25-045) [ADAMS Accession No. ML25079A198], Dominion Energy South Carolina, Inc. (DESC), submitted a License Amendment Request (LAR) to revise Technical Specification (TS) 6.8.4.g, "Containment Leakage Rate Testing Program," to adopt NEI 94-01, Revision 3-A and the NRC conditions in Revision 2-A. The LAR requests approval to extend the Type C Local Leak Rate Testing (LLRT) intervals from 60 to 75 months on a performance-based basis in accordance with 10 CFR Part 50, Appendix J, Option B.
By email dated July 30, 2025, [ADAMS Accession No. ML25211A229], the NRC technical staff identified four areas requiring additional information (3 Requests for Additional Information (RAIs) and 1 Request for Confirmation of Information (RCI)) to facilitate their review of the proposed LAR. The NRC¶s request and DESC¶s response are provided in this attachment.
RAI 1: Justification for Adjustment Factor The LAR applies a 1.25 multiplier to as-left Type C LLRT results when evaluating valves tested beyond 60 months. NEI 94-01 does not direct or endorse the use of this multiplier.
Please provide a technical basis or bounding analysis demonstrating the conservatism and applicability of the 1.25 factor across degradation mechanisms and valve types.
Alternatively, clarify whether the interval extension can be justified solely based on historical performance trends.
DESC Response to RAI 1 As discussed in LAR 25-045, Attachment 1, Section 3.4, subsection titled ³Response to Condition 2, ISSUE 1,' DESC has chosen to apply a potential leakage understatement factor of 1.25 to the actual As-Left leak rate for each Type C component currently on greater than a 60-month test interval, up to the 75-month extended test interval.
The proposed extension from 60-months to 75-months would represent an increase of 25% in the LLRT periodicity. Increasing the As-Left leakage rates of those Type C components that have been placed on a 75-month LLRT interval by 25% is equivalent to applying a potential leakage understatement adjustment factor of 1.25. Conservatively applying this 1.25 potential leakage understatement adjustment factor to the actual As-Left leak rate, which will increase the As-Left leakage rate for each Type C component currently on greater than a 60-month test interval up to the 75-month extended test interval, will result in a combined conservative Type C total for all 75-month LLRTs being
Serial No. 25-045B Docket No. 50-395 Attachment, Page 2 of 14
³carried forward' and will be included whenever the total leakage summation must be updated (either while on-line or following an outage).
The Minimum Pathway Leak Rate (MNPLR) is the combination of: (1) the potential leakage understatement adjusted leak rate total for those Type C components being tested on greater than a 60-month test interval up to the 75-month extended test interval, (2) the non-adjusted total of the Type C components being tested at less than or equal to a 60-month test interval, and (3) the total of the Type B test components. If the potential leakage understatement adjusted MNPLR is greater than the VCSNS administrative leakage summation limit of 0.5 La, but less than the regulatory limit of 0.6 La, then an analysis and corrective action plan shall be prepared to restore the leakage summation value to less than the VCSNS administrative leakage summation limit. The corrective action plan should focus on those components that have contributed the most to the increase in the leakage summation value and what manner of timely corrective action, as deemed appropriate, best focuses on the prevention of future component leakage performance issues to maintain an acceptable level of margin.
If the potential leakage understatement adjusted MNPLR is less than the VCSNS administrative leakage summation limit of 0.5 La, then the acceptability of the greater than a 60-month test interval up to the 75-month LLRT extension for all affected Type C components has been adequately demonstrated and the calculated local leak rate total represents the actual leakage potential of the penetration.
The application of a potential leakage understatement factor of 1.25 and the use of an administrative leakage summation limit of 0.5 La to meet Topical Report Condition 1 and Topical Report Condition 2, Issues 1 and 2 of NEI 94-01, Revision 3-A, has been previously approved by the NRC in the associated Safety Evaluation Reports (SERs):
Salem Nuclear Generating Station, Units 1 and 2, issued May 29, 2024 (ADAMS Accession No. ML24099A157).
Callaway Plant, Unit 1, issued September 25, 2023 (ADAMS Accession No. ML23228A025).
Palo Verde Nuclear Generating Station, Units 1, 2, and 3, issued December 22, 2021 (ADAMS Accession No. ML21347A003).
Shearon Harris Nuclear Power Plant, Unit 1, issued December 8, 2020 (ADAMS Accession No. ML20259A512).
Wolf Creek Generating Station, Unit 1, issued December 7, 2020 (ADAMS Accession No. ML20276A149).
Serial No. 25-045B Docket No. 50-395 Attachment, Page 3 of 14 RAI 2: LLRT Performance Trend Analysis The LAR includes as-found and as-left Type C LLRT data but does not provide a performance trend analysis. Please provide a graphical or tabular trend evaluation of the LLRT data over the past 10 years. Include identification of any recurring valve failures, corrective actions, and justification for continued eligibility for extended intervals.
DESC Response to RAI 2 The data contained within LAR 25-045, Attachment 2, Table 2-1, Type B and Type C LLRT Combined As-Found/As-Left Trend Summary, which provides the LLRT data trend summaries for VCSNS since 2014 has been supplemented with ³Figure NRC RAI 2,' a graphical representation of the As-Found Minimum Pathway, As-Left Maximum Pathway, and As-Left Minimum Pathway summations in standard cubic centimeters per minute (sccm). These summation totals for each outage are displayed against La, equal to 294,705 sccm, and 0.6 La, equal to 176,823 sccm, in accordance with Technical Specification 6.8.4.g. ³Figure NRC RAI 2' illustrates that results are not adversely trending towards the limits.
The data contained within LAR 25-045, Attachment 2, Table 2-2, Types B and C LLRT Program Implementation Review, which identifies the components that have not demonstrated acceptable performance during the previous three outages for VCSNS has been supplemented with the below tables identifying the components that have not demonstrated acceptable performance for VCSNS for the prior five outages. Together, these tables detail the Type C failures for the last 10 years and include the corrective actions taken.
As noted in LAR 25-045, Attachment 2, Table 2-2 and the supplemental tables below, DESC does not justify continued eligibility for extended intervals for any components that have not demonstrated acceptable performance. In accordance with the requirements of NEI 94-01, Revisions 2-A and 3-A, Section 10.2, ³Type B and Type C Testing Frequencies,' leakage rates that exceed the administrative leakage rate limits are not acceptable. When these limits are exceeded, the testing frequency is returned to the baseline testing frequency of at least once per 30 months (i.e., each outage) until adequate performance has been reestablished. Additionally, a cause determination is performed, and corrective actions are identified as necessary to eliminate the identified cause of a Type C leak rate exceeding the administrative limit. Extensions of Type C test intervals are allowed based upon completion of two consecutive periodic As-Found Type C tests where the result is within the administrative limits.
As demonstrated in LAR 25-045, Attachment 2, Table 2-2 and the supplemental tables below, recurring valve failures have been generally minimized over the last 10 years and corrective actions have been effective in restoring performance within administrative limits. Therefore, the Type B and Type C component performance at VCSNS, combined
Serial No. 25-045B Docket No. 50-395 Attachment, Page 4 of 14 with the corrective action processes in place, justify the extension of Type C LLRT intervals from 60 to 75 months.
0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 2014 (RF-21) 2015 (RF-22) 2017 (RF-23) 2018 (RF-24) 2020 (RF-25) 2021 (RF-26) 2023 (RF-27) 2024 (RF-28) sccm Year (Outage)
Types B and C LLRT Combined As-Found/As-Left Trend AF Min Path (sccm)
AL Max Path (sccm)
AL Min Path (sccm) 0.6 La La
Serial No. 25-045B Docket No. 50-395 Attachment, Page 6 of 14 Table NRC RAI 2: Types B and C LLRT Program Implementation Review Supplement Component
[Penetration No.]
As-Found (sccm)
Admin Limit (sccm)
As-Left (sccm)
Cause of Failure Corrective Action Scheduled Interval 2014 RF-21 XVC07541-AC / XVG07502-AC AC Supply Header Containment Isolation Valve Bypass Check Valve /
AC Supply Header Containment Isolation Valve
[XRP0208]
14,360 2,720 4,950 XVG07502-AC Valve Actuator (6)
Interval remained on baseline XVC02913-SA Reactor Building SA Header Check Valve (IRC)
[XRP0310]
(5) 2,015 350 Corrosion on Valve Internals Clean valve internals Interval remained on baseline XVC06799-FS XAA0004A, 4B FS Supply Header Check Valve
[XRP0427]
3,400 2,015 386 Corrosion on Valve Internals Clean valve internals Interval reset to baseline NOTES:
(5) XVC02913-SA was unable to be pressurized to obtain an AF LLRT leakage value. Opened valve and found disc rusted to valve body. Following maintenance to clean disc and valve body, AL LLRT performed with leakage measured at 350 sccm.
(6) Suspected XVC07541-AC leaking by. Disassembled XVC07541-AC and found rust and dirt on seat, cleaned and reassembled. Following maintenance, AL LLRT performed with XVC07541-AC/XVG07502-AC leakage measured at 6,820 sccm. Disassembled XVC09541-AC a second time and cleaned, no issues noted with XVC07541-AC during disassembly. AL LLRT Retest performed with XVC07541-AC/XVG07502-AC leakage measured at 4,950 sccm. Troubleshooting confirmed XVG07502-AC leaking by. Evaluated for continued service as closure torque for XVG07502-AC was left at close to the maximum setting. XVG07502-AC recommended for MOV overhaul in RF-22. (During RF-24, XRP0208 was modified under ECR-50917 to a typical spare penetration and the containment isolation valves associated with XRP0208 were removed.)
Serial No. 25-045B Docket No. 50-395 Attachment, Page 7 of 14 Table NRC RAI 2: Types B and C LLRT Program Implementation Review Supplement (continued)
Component
[Penetration No.]
As-Found (sccm)
Admin Limit (sccm)
As-Left (sccm)
Cause of Failure Corrective Action Scheduled Interval 2015 RF-22 XVC08381-CS CVCS Charging Header Check Valve (IRC)
[XRP0409]
2,360 2,015 238 Not Determined None Performed Interval reset to baseline XVG08107-CS Charging Pumps Discharge Header Isolation Valve
[XRP0409]
2,500 2,015 128 Degraded Packing Packing Replaced Interval reset to baseline XVT02660-IA RB IA Air Supply Isolation Valve (ORC)
[XRP0311]
1,231 2,015 2,400 AOV Overhaul (7)
Interval reset to baseline NOTES:
(7) AF LLRT performed on XVT02660-IA during RF-22 prior to performing overhaul of AOV. Following maintenance and diagnostics on XVT02660-IA, AL LLRT performed with XVT02660-IA leakage measured at 2,400 sccm. Evaluated for continued service as leak rate was below surveillance limit of 2,520 sccm. Work Order written to increase seat load and adjust valve as necessary to restore leak rate to below admin limit.
Serial No. 25-045B Docket No. 50-395 Attachment, Page 8 of 14 Table NRC RAI 2: Types B and C LLRT Program Implementation Review Supplement (continued)
Component
[Penetration No.]
As-Found (sccm)
Admin Limit (sccm)
As-Left (sccm)
Cause of Failure Corrective Action Scheduled Interval 2017 RF-23 XVD06671-SF / XVD06672-SF Refuel Cavity SF Purification Suction Isolation (IRC) /
Refuel Cavity SF Purification Supply Isolation Valve
[XRP0419]
(8) 2,015 35.2 (8)
(8)
Interval reset to baseline XVG06797-FS RB Sprinkler System Supply Header Isolation Valve
[XRP0427]
3,100 2,015 (9)
(9)
(9)
Interval remained on baseline NOTES:
(8) AF LLRT was not performed on XVD06671-SF/XVD06672-SF during RF-23 prior to valve diaphragms being replaced. Following completion of maintenance, AL LLRT performed with XVD06671-SF/XVD06672-SF leakage measured at 35.2 sccm.
(9) AF LLRT performed on XVG06797-FS during RF-23 with leakage measured at 3,100 sccm, exceeding administrative limit of 2,015 sccm and surveillance limit of 2,520 sccm. Cause believed to be corrosion, due to Fire Service system being raw water. Evaluated for continued service. Work Order written to clean/inspect valve and correct cause of leakage in RF-24.
Serial No. 25-045B Docket No. 50-395 Attachment, Page 9 of 14 Table NRC RAI 2: Types B and C LLRT Program Implementation Review Supplement (continued)
Component
[Penetration No.]
As-Found (sccm)
Admin Limit (sccm)
As-Left (sccm)
Cause of Failure Corrective Action Scheduled Interval 2018 RF-24 XVC02913-SA RB SA Header Check Valve
[XRP0310]
(10) 2,015 1,590 Corrosion on Valve Internals Clean valve internals Interval remained on baseline XVC08947-SI SI Accumulator Nitrogen Supply Check Valve
[XRP0320]
2,240 2,015 1,873 Not Determined (11)
Interval reset to baseline XVC09689-CC / XVG09605-CC RB CC Return Header Isolation Valve Bypass Check Valve /
RB CC Return Header Isolation Valve
[XRP0330]
(12) 2,920 2,840 XVC09689-CC Valve Internals (12)
Interval remained on baseline NOTES:
(10) XVC02913-SA unable to be pressurized due to gross leakage during AF LLRT. Opened valve and cleaned out debris from between valve seat and disc. AL LLRT performed with leakage measured at 1,590 sccm. PM created to clean valve internals due to LLRT history.
(11) Following failed AF LLRT, opened valve and found no wear or damage. Lapped disc/seat and inspected spring. AL LLRT performed with leakage measured at 1,873 sccm.
(12) XVC09689-CC/XVG09605-CC unable to be pressurized due to gross leakage during AF LLRT. Troubleshooting confirmed XVC09689-CC leaking by. Opened valve and cleaned out small amount of debris from between valve seat and disc. AL LLRT performed with leakage measured at 2,840 sccm. (During RF-27, modification VC-22-00005 implemented to replace swing-check valve XVC09689-CC with a soft-seated piston-check.)
Serial No. 25-045B Docket No. 50-395 Attachment, Page 10 of 14 Table NRC RAI 2: Types B and C LLRT Program Implementation Review Supplement (continued)
Component
[Penetration No.]
As-Found (sccm)
Admin Limit (sccm)
As-Left (sccm)
Cause of Failure Corrective Action Scheduled Interval 2020 RF-25 XVC03009B-SP RB Spray Nozzle Inlet Header Check Valve
[XRP0303]
19,670 3,225 793 Boron Deposits on Valve Internals Clean valve internals Interval reset to baseline XVT02662A-IA RB IA Suction Isolation Valve (ORC)
[XRP0319]
3,800 2,720 818 (13)
(13)
Interval reset to baseline XVC08947-SI SI Accumulator Nitrogen Supply Check Valve
[XRP0320]
3,210 2,015 1,582 Corrosion on Valve Internals Clean valve internals Interval remained on baseline XVC09689-CC / XVG09605-CC RB CC Return Header Isolation Valve Bypass Check Valve /
RB CC Return Header Isolation Valve
[XRP0330]
(14) 2,920 109 (14)
(14)
Interval remained on baseline XVG06797-FS RB Sprinkler System Supply Header Isolation Valve
[XRP0427]
3,850 2,015 3,850 (15)
(15)
Interval remained on baseline
Serial No. 25-045B Docket No. 50-395 Attachment, Page 11 of 14 Table NRC RAI 2: Types B and C LLRT Program Implementation Review Supplement (continued) 2020 RF-25 (continued)
NOTES:
(13) Following failed AF LLRT, diagnostics performed on AOV with no abnormalities noted, benchset adjusted and AL LLRT performed with XVT02662A-IA leakage measured at 7,200 sccm. Corrective maintenance to disassemble/inspect operator, replace soft goods, and replace springs completed. Valve body disassembled and cleaned with corrosion noted on seating area. AL LLRT Retest performed with XVT02662A-IA leakage measured at 818 sccm.
(14) AF LLRT performed on XVG06797-FS during RF-25 with leakage measured at 3,850 sccm, exceeding administrative limit of 2,015 sccm and surveillance limit of 2,520 sccm. Cause believed to be corrosion, due to Fire Service system being raw water. Evaluated for continued service. Work Order written to repair/refurbish XVG06797-FS in RF-26.
(15) XVC09689-CC/XVG09605-CC unable to be pressurized due to gross leakage during AF LLRT. No valve work on XVG09605-CC was performed during RF-25 and troubleshooting confirmed XVC09689-CC leaking by. Disassembled, cleaned, and inspected XVC09689-CC with no significant findings. AL LLRT performed with leakage measured at 109 sccm. (During RF-27, modification VC-22-00005 implemented to replace swing-check XVC09689-CC with a soft-seated piston-check.)
Serial No. 25-045B Docket No. 50-395 Attachment, Page 12 of 14 RAI 3: Aging and Structural Integrity Evaluation The LAR describes containment penetration types but does not address aging mechanisms for components on 75-month test intervals. Please describe how aging effects such as material degradation, seal embrittlement, or mechanical fatigue are evaluated and monitored for extended-interval components. Include references to any aging management or surveillance programs, if applicable.
DESC Response to RAI 3 VCSNS Final Safety Analysis Report (FSAR) Chapter 18 addresses aging management programs and activities. VCSNS Subsequent License Renewal Application (SLRA),
Appendix A, FSAR Supplement, submitted August 2023 [ADAMS Accession No. ML23233A172], includes information that replaces FSAR Chapter 18. VCSNS FSAR Chapter 18 will be updated in accordance with VCSNS Unit 1 SLRA SER [ADAMS Accession Package No. ML25059A003], Section 1, Subsection 1.7.
SLRA Section A1.33 of Appendix A contains a summary description of the 10 CFR Part 50, Appendix J, aging management program (AMP) used to manage the effects of aging during the subsequent period of extended operation. This AMP is consistent with generally accepted industry methods as discussed in NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report. Section A1.33 states in part:
³The 10 CFR Part 50, Appendix J program is an existing performance monitoring program that manages cracking, loss of leak tightness, loss of material, loss of preload and loss of sealing. Leakage rates through the Containment pressure boundary are monitored, including the Containment liner, associated welds, penetrations, isolation valves, fittings, and other access openings to detect degradation of the Containment pressure boundary. Corrective actions are taken if leakage rates exceed acceptance criteria.'
SLRA Section A3.6 of Appendix A contains evaluation summaries of time-limited aging analyses (TLAA) for the subsequent period of extended operation for the Containment Liner Plate and Penetrations Fatigue Analysis.
SLRA Section A3.6.1, Containment Liner Plate, states in part that:
³The original design analysis for the containment liner plate and penetration sleeves included a fatigue waiver which demonstrated that all six requirements of the ASME Code were met, providing the basis to conclude that no fatigue analysis was required for these components. The anticipated startup/shutdown cycles in the fatigue waiver were extrapolated for an 80-year operating period and demonstrate that the six conditions in the ASME Code continue to be met and therefore, no fatigue analysis is required through the subsequent period of extended operation. The fatigue waiver for
Serial No. 25-045B Docket No. 50-395 Attachment, Page 13 of 14 the Containment liner and penetration sleeves was revised for 80 years and has been projected to the end of the subsequent period of extended operation.'
SLRA Section A3.6.3, Containment Penetrations Fatigue Analysis, states in part that:
³The Reactor Building main steam penetrations were designed in accordance with ASME Section III, 1974 Edition through Winter, 1975 Addenda and identified as a TLAA. No other Reactor Building penetrations meet the criteria to be considered TLAAs. The Reactor Building main steam penetrations consist of three main components. The first is the penetration sleeve, which was evaluated with the containment liner (Section A3.6.1). The remaining components include the section of process pipe passing through the penetration and the attachment assemblies both inside and outside of the containment wall that connect the process pipe to the sleeve.
Together, the two remaining parts of the main steam penetrations make up the main steam penetrations internals and have a design analysis that demonstrates the 40-year design transient cycles continue to bound the 80-year projected cycles.
Therefore, the TLAA will remain valid for the subsequent period of extended operation.'
VCSNS SLRA, Appendix B, Aging Management Programs, includes descriptions of each of the AMPs credited for managing the effects of aging consistent with NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report.
SLRA Section B2.1.33, 10 CFR Part 50, Appendix J, contains a description of the VCSNS AMP and states in part that:
³Containment leak rate tests are performed to verify that leakage through the Containment, and systems and components penetrating the Containment, remains below Technical Specification allowable limits. An integrated leak rate test is performed during unit shutdown at an interval based on the historical performance of the overall Containment system. A general visual inspection of accessible interior and exterior surfaces of the Containment structure is conducted at intervals that comply with Appendix J to Title 10 of the Code of Federal Regulations (10 CFR) Part 50. Local leak rate tests are performed on Containment access penetrations and Containment isolation valves at intervals that comply with 10 CFR Part 50, Appendix J, Option B.
Visual inspections of the accessible interior and exterior surfaces of the Containment structure and components, performed by the ASME Section XI, Subsection IWE program (B2.1.30) and the ASME Section XI, Subsection IWL program (B2.1.31),
augment the 10 CFR Part 50, Appendix J program leakage rate testing and detect evidence of structural degradation that may affect the Containment structure leakage integrity.
The aging effects associated with the Containment pressure boundary components within the scope of subsequent license renewal and excluded from Type B or C
Serial No. 25-045B Docket No. 50-395 Attachment, Page 14 of 14 Appendix J local leak rate testing are managed by the following aging management programs:
Water Chemistry program (B2.1.2)
Flow-Accelerated Corrosion program (B2.1.8)
Closed Treated Water Systems program (B2.1.12)
Compressed Air Monitoring program (B2.1.14)
Fire Water System program (B2.1.16)
One-Time Inspection program (B2.1.20)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.25)
ASME Section XI, Subsection IWE program (B2.1.30)
Environmental Qualification of Electric Equipment program (B3.3)'
SLRA Section B2.1.33, 10 CFR Part 50, Appendix J, concludes that ³the continued implementation of the 10 CFR Part 50, Appendix J program provides reasonable assurance that aging effects will be managed such that the components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis during the subsequent period of extended operation' and did not identify any necessary enhancements to the AMP.
The NRC approved the adequacy of these existing Programs as part of their SER for the VCSNS SLRA, dated March 4, 2025 [ADAMS Accession Package No. ML25059A003].
Thus, the Programs are intended to remain in effect for future operation at VCSNS and support the extension of Type C LLRT intervals from 60 to 75 months.
RCI 1: NEI 94-01 Condition 2, Visual Inspection Frequency NEI 94-01, Rev. 2-A, Condition 2 requires that at least three visual inspections of the containment be performed during each 15-year Type A test interval. Please confirm that the containment inspection program ensures this frequency and that the inspections are consistent in scope with ASME Section XI, Subsections IWE and IWL.
DESC Response to RCI 1 This information has been confirmed to be correct as stated.