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| {{#Wiki_filter:From: Sayoc, Emmanuel To: Paul Aitken | | {{#Wiki_filter:From: Sayoc, Emmanuel To: Paul Aitken; Eric A Blocher Cc: Wu, Angela |
| ; Eric A Blocher Cc: Wu, Angela | |
|
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| ==Subject:== | | ==Subject:== |
| Draft RAI Surry TRP 20 Open Cycle Cooling Water Date: Tuesday, June 11, 2019 10:23:00 AM Attachments: | | Draft RAI Surry TRP 20 Open Cycle Cooling Water Date: Tuesday, June 11, 2019 10:23:00 AM Attachments: 020 Surry OCCW RAI Gavula Johnson.docx Paul, Eric, I am hoping this is the last RAI. Do you need a clarification call? |
| 020 Surry OCCW RAI Gavula Johnson.docx Paul, Eric, I am hoping this is the last RAI. Do you need a clarification call? | | Emmanuel Manny Sayoc Safety Project Manager NRR/DLR 301-415-4084 |
| Emmanuel "Manny" Sayoc Safety Project Manager NRR/DLR 301-415-4084 Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As provided in §54.29(a), a renewed license may be issued if the staff finds that actions have been identified, which either have been or will be taken, with respect to managing the effects of aging during the period of extended operation. As described in the Standard Review Plan for Subsequent License Renewal (SLR), an applicant may reference the GALL | |
| -SLR Report in a subsequent license renewal application (SLRA) to designate which aging management programs will be used and how they correspond to the programs in the GALL
| |
| -SLR Report. If an applicant takes credit for a program in the GALL
| |
| -SLR Report, it is incumbent on the applicant to ensure the conditions and operating experience at t he plant are bounded by those for which the GALL
| |
| -SLR Report aging management program (AMP) was evaluated. To complete its review and enable the formulation of a finding under §54.29(a), the staff requires additional information regarding the matters described below.
| |
| RAI B2.1.11
| |
| -1 Generic Letter 89
| |
| -13 Commitments Background. GALL-SLR AMP XI.M20, "Open
| |
| -Cycle Cooling Water System," states that the inspection scope, methods, and frequencies are in accordance with the applicant's docketed response to Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety
| |
| -Related Components." SLRA Section B2.1.11, "Open
| |
| -Cycle Cooling Water System," states that the program is an existing program that, following enhancement, will be consistent with the GALL-SLR AMP XI.M20. SLRA Section B2.1.11 also states that periodic heat transfer testing, visual inspection, and cleaning of safety
| |
| -related heat exchangers is performed in accordance with the site commitments to GL 89
| |
| -13. ETE-SLR-2018-1314, "Aging Management Program Evaluation Report
| |
| - Open-Cycle Cooling Water System,"
| |
| Revision 2, document s and evaluate s the activities in the associated AMP that are credited for managing aging as part of Surry's SLRA. ETE
| |
| -SLR-2018-1314 discusses a discrepancy between Surry's response to GL 89
| |
| -13 (letter dated October 2, 1991 (89
| |
| -572G)) and the maintenance strategy implementation for the charging pump lube oil coolers. The maintenance strategy changed from periodic replacement of charging pump lube oil coolers to performing routine inspection and maintenance. ETE
| |
| -SLR-2018-1314 states that the discrepancy was evaluated in accordance with the commitment change evaluation process and cites corrective action CA3022000 "Submit Commitment Change Paperwork to Update Requirements for Charging Pump LO [Lube Oil] Coolers" (March 9, 2017). The staff noted th at the change in maintenance strategy affected the scope of Surry's Open
| |
| -Cycle Cooling Water System program, because components that are periodically replaced are excluded from the scope of an aging management review for license renewal.
| |
| In response to staff questions for CA3022000, Surry posted condition report CR1091365, (March 6, 2018) "A Commitment Change Evaluation Was Completed and Approved Mistakenly." The condition report stat es that the commitment change evaluation was "for a change made to a response to the NRC, not a commitment to the NRC.
| |
| " The actions discussed in the condition report included a clarification regarding "the difference between a response and a commitment to the NRC."
| |
| During its review of ER-SU-5314, "Generic Letter 89
| |
| -13 Program," Revision 2, the staff noted that Attachment 1, "Generic Letter 89
| |
| -13 Components and Commitments," includes a table for each set of components in the program and includes a column labeled "Commitment Source." Every set of component s in the list incl ude s "Letter to NRC 10/2
| |
| /91 Serial Number 89
| |
| -572G" as the source of the commitment to perform the specified GL 89
| |
| -13 activity
| |
| . However, the table's initial note states that the letter dated April 30, 1991 (Serial 89
| |
| -572E), summarized the GL 89-13 program and that the response was updated by letter dated October 2, 1991 (Serial 89
| |
| -572G), "which supersedes Serial Number 89
| |
| -572E. No new commitments were made."
| |
| The staff notes that the letter dated April 30, 1991 (Serial 89
| |
| -572 E), states that a "detailed revision of [Surry's] initial January 29, 1990, response incorporating the subsequent supplements and the additions integrated into this summary description will be separately forwarded." In addition, the staff notes that none of the GL 89
| |
| -13 response letters appear to specifically identify the site's activities for periodic heat transfer testing, visual inspection, and cleaning of safety
| |
| -related heat exchangers as being "commitments.
| |
| " Issue. Because none of the site's GL 89-13 response letters appear to specifically identify the commitments for periodic heat transfer testing, visual inspection, and cleaning of safety
| |
| -related heat exchangers, the staff was unable to verify that the Open
| |
| -Cycle Cooling Water System program would be performed in accordance with the site's commitments to GL 89-13. The program documentation appears to cite the letter dated October 2, 1991 (89
| |
| -572G), as the source of the site's GL 89
| |
| -13 commitments. However, the recent condition report (CR1091365) states that because the information in the October 2, 1991, letter was only a response to GL 89-13 and not a commitment, there was no need to perform a commitment change evaluation for changing the approach discussed in the October 2, 1991, letter. Based on the position discussed in CR1091365, the staff is unsure of the site's GL 89
| |
| -13 commitments.
| |
| Request. Provide additional information to clarify the site's GL 89
| |
| -13 commitments. Include information about which prior GL 89
| |
| -13 response letter(s) to the NRC contain (s) the commitments that are discussed in SLRA Section B2.1.11. If the source of Surry's commitments to GL 89
| |
| -13 are not from the response dated October 2, 1991 (89
| |
| -572G), also include information regarding the circumstances about why ER-SU-5314, "Generic Letter 89
| |
| -13 Program," Revision 2 , cites the letter dated October 2, 1991 (89
| |
| -572G). RAI B2.1.11
| |
| -2 AMR Items for Open
| |
| -Cycle Cooling Water System Background. SLRA Section B2.1.11, "Open-Cycle Cooling Water System," states that periodic heat transfer testing, visual inspection, and cleaning of heat exchangers are performed in accordance with the site commitments to GL 89
| |
| -13 to verify heat transfer capabilities. SLRA Section B2.1.11 also includes an enhancement to the monitoring and trending program element to revise procedures to require trending the inspection results of the emergency service water pump engine heat exchanger
| |
| : s. The staff notes th at ER-SU-5314, "Generic Letter 89-13 Program," Revision 2, includes the emergency service water pump engine heat exchanger and specifies associated activities for periodic heat transfer testing
| |
| , as well as inspection and maintenance. In addition, ER
| |
| -SU-5314 includes the emergency service water pump angle drive and specifies that heat transfer is checked during monthly surveillance testing, and that cooling water flow is verified during inspection and maintenance activities.
| |
| Although SLRA Table 3.3.2
| |
| -4 "Service Water
| |
| - Aging Management Evaluation," includes other emergency service water pump components, it does not appear to include the emergency service water pump engine heat exchanger or the emergency service water pump angle drive.
| |
|
| |
|
| Issue. Although SLRA Section B2.1.11 includes an enhancement to trend inspection results associated with emergency service water pump engine heat exchangers, the SLRA does not appear to include a corresponding aging management review item(s). In addition, although Surry's GL 89 | | Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As provided in §54.29(a), a renewed license may be issued if the staff finds that actions have been identified, which either have been or will be taken, with respect to managing the effects of aging during the period of extended operation. |
| -13 program appears to specify activities to address heat transfer for the emergency service water pump angle drive, the SLRA does not appear to include a corresponding aging management review item. | | As described in the Standard Review Plan for Subsequent License Renewal (SLR), an applicant may reference the GALL-SLR Report in a subsequent license renewal application (SLRA) to designate which aging management programs will be used and how they correspond to the programs in the GALL-SLR Report. If an applicant takes credit for a program in the GALL-SLR Report, it is incumbent on the applicant to ensure the conditions and operating experience at the plant are bounded by those for which the GALL-SLR Report aging management program (AMP) was evaluated. To complete its review and enable the formulation of a finding under §54.29(a), |
| Request. For the emergency service water pump engine heat exchangers and the emergency service water pump angle drives, provide information showing that assessment of the heat transfer capabilities of safety | | the staff requires additional information regarding the matters described below. |
| -related heat exchangers (with a heat transfer intended function | | RAI B2.1.11-1 Generic Letter 89-13 Commitments Background. GALL-SLR AMP XI.M20, Open-Cycle Cooling Water System, states that the inspection scope, methods, and frequencies are in accordance with the applicants docketed response to Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Components. SLRA Section B2.1.11, Open-Cycle Cooling Water System, states that the program is an existing program that, following enhancement, will be consistent with the GALL-SLR AMP XI.M20. SLRA Section B2.1.11 also states that periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers is performed in accordance with the site commitments to GL 89-13. |
| ) will be performed by the SLRA Section B2.1.11, "Open | | ETE-SLR-2018-1314, Aging Management Program Evaluation Report - Open-Cycle Cooling Water System, Revision 2, documents and evaluates the activities in the associated AMP that are credited for managing aging as part of Surrys SLRA. ETE-SLR-2018-1314 discusses a discrepancy between Surrys response to GL 89-13 (letter dated October 2, 1991 (89-572G)) |
| -Cycle Cooling Water System" program, in accordance with site commitments to GL 89 | | and the maintenance strategy implementation for the charging pump lube oil coolers. The maintenance strategy changed from periodic replacement of charging pump lube oil coolers to performing routine inspection and maintenance. ETE-SLR-2018-1314 states that the discrepancy was evaluated in accordance with the commitment change evaluation process and cites corrective action CA3022000 Submit Commitment Change Paperwork to Update Requirements for Charging Pump LO [Lube Oil] Coolers (March 9, 2017). The staff noted that the change in maintenance strategy affected the scope of Surrys Open-Cycle Cooling Water System program, because components that are periodically replaced are excluded from the scope of an aging management review for license renewal. |
| -13. Include information showing either 1) that existing aging management review items with corresponding aging effects are included in the SLRA for these components or 2) that aging management review items are not needed for these components, to demonstrate that the effects of aging will be adequately managed.}} | | In response to staff questions for CA3022000, Surry posted condition report CR1091365, (March 6, 2018) A Commitment Change Evaluation Was Completed and Approved Mistakenly. |
| | The condition report states that the commitment change evaluation was for a change made to a response to the NRC, not a commitment to the NRC. The actions discussed in the condition report included a clarification regarding the difference between a response and a commitment to the NRC. |
| | During its review of ER-SU-5314, Generic Letter 89-13 Program, Revision 2, the staff noted that Attachment 1, Generic Letter 89-13 Components and Commitments, includes a table for each set of components in the program and includes a column labeled Commitment Source. |
| | Every set of components in the list includes Letter to NRC 10/2/91 Serial Number 89-572G as |
| | |
| | the source of the commitment to perform the specified GL 89-13 activity. However, the tables initial note states that the letter dated April 30, 1991 (Serial 89-572E), summarized the GL 89-13 program and that the response was updated by letter dated October 2, 1991 (Serial 89-572G), |
| | which supersedes Serial Number 89-572E. No new commitments were made. |
| | The staff notes that the letter dated April 30, 1991 (Serial 89-572E), states that a detailed revision of [Surrys] initial January 29, 1990, response incorporating the subsequent supplements and the additions integrated into this summary description will be separately forwarded. In addition, the staff notes that none of the GL 89-13 response letters appear to specifically identify the sites activities for periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers as being commitments. |
| | Issue. Because none of the sites GL 89-13 response letters appear to specifically identify the commitments for periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers, the staff was unable to verify that the Open-Cycle Cooling Water System program would be performed in accordance with the sites commitments to GL 89-13. The program documentation appears to cite the letter dated October 2, 1991 (89-572G), as the source of the sites GL 89-13 commitments. However, the recent condition report (CR1091365) states that because the information in the October 2, 1991, letter was only a response to GL 89-13 and not a commitment, there was no need to perform a commitment change evaluation for changing the approach discussed in the October 2, 1991, letter. Based on the position discussed in CR1091365, the staff is unsure of the sites GL 89-13 commitments. |
| | Request. Provide additional information to clarify the sites GL 89-13 commitments. Include information about which prior GL 89-13 response letter(s) to the NRC contain(s) the commitments that are discussed in SLRA Section B2.1.11. If the source of Surrys commitments to GL 89-13 are not from the response dated October 2, 1991 (89-572G), also include information regarding the circumstances about why ER-SU-5314, Generic Letter 89-13 Program, Revision 2, cites the letter dated October 2, 1991 (89-572G). |
| | RAI B2.1.11-2 AMR Items for Open-Cycle Cooling Water System Background. SLRA Section B2.1.11, Open-Cycle Cooling Water System, states that periodic heat transfer testing, visual inspection, and cleaning of heat exchangers are performed in accordance with the site commitments to GL 89-13 to verify heat transfer capabilities. SLRA Section B2.1.11 also includes an enhancement to the monitoring and trending program element to revise procedures to require trending the inspection results of the emergency service water pump engine heat exchangers. |
| | The staff notes that ER-SU-5314, Generic Letter 89-13 Program, Revision 2, includes the emergency service water pump engine heat exchanger and specifies associated activities for periodic heat transfer testing, as well as inspection and maintenance. In addition, ER-SU-5314 includes the emergency service water pump angle drive and specifies that heat transfer is checked during monthly surveillance testing, and that cooling water flow is verified during inspection and maintenance activities. |
| | Although SLRA Table 3.3.2-4 Service Water - Aging Management Evaluation, includes other emergency service water pump components, it does not appear to include the emergency service water pump engine heat exchanger or the emergency service water pump angle drive. |
| | |
| | Issue. Although SLRA Section B2.1.11 includes an enhancement to trend inspection results associated with emergency service water pump engine heat exchangers, the SLRA does not appear to include a corresponding aging management review item(s). In addition, although Surrys GL 89-13 program appears to specify activities to address heat transfer for the emergency service water pump angle drive, the SLRA does not appear to include a corresponding aging management review item. |
| | Request. For the emergency service water pump engine heat exchangers and the emergency service water pump angle drives, provide information showing that assessment of the heat transfer capabilities of safety-related heat exchangers (with a heat transfer intended function) will be performed by the SLRA Section B2.1.11, Open-Cycle Cooling Water System program, in accordance with site commitments to GL 89-13. Include information showing either 1) that existing aging management review items with corresponding aging effects are included in the SLRA for these components or 2) that aging management review items are not needed for these components, to demonstrate that the effects of aging will be adequately managed.}} |
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[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23187A1122023-07-0606 July 2023 TSC Relocation LAR RAIs ML23171B0522023-06-20020 June 2023 NRR E-mail Capture - RAI for Review of Appendix F to DOM-NAF-2-P (Redacted) ML23068A0242023-03-0808 March 2023 RAI Issuance Fuel Handling Trolley LAR ML23054A2412023-02-23023 February 2023 NRR E-mail Capture - Formal Issuance of RAIs for Surry Turbine Building Tornado Reclassification ML23046A1172023-02-0202 February 2023 002 Radiation Safety Baseline Inspection Information Request ML23018A1642023-01-17017 January 2023 Formal Issuance of RAIs for Surry ISI Alternative for SG Welds, 30 Day Calendar Response Period (Email) ML22349A2102022-12-15015 December 2022 Formal 43-day Request for Additional Information Issuance for Surry Turbine Building License Amendment Request ML22339A1582022-11-30030 November 2022 Requalification Inspection Notification Letter ML22258A2202022-09-13013 September 2022 FFD RFI ML22251A1292022-09-0909 September 2022 Request for Additional Information Related to Response to Generic Letter 2004-04 ML22242A0452022-08-23023 August 2022 NRR E-mail Capture - Dominion GL 04-02 Response Draft RAIs (L-2017-LRC-0000) ML22223A1192022-08-14014 August 2022 RP Inspection Document Request Letter Final ML22110A2052022-04-19019 April 2022 Formal Issuance of RAIs for Post LOCA Buffer Change LAR ML22067A1622022-03-0909 March 2022 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML22012A0572022-01-11011 January 2022 Issuance of RAIs for Surry Unit 1, Spring 2021 Steam Generator Tube Inspection ML21225A5022021-08-13013 August 2021 Request for Additional Information for North Anna Power Station, Units 1 and 2, Surry Power Station, Units 1 and 2, and Millstone Power Station, Units 2 and 3, Appendix E of Fleet Report Com-Naf-2 (EPID:L02021-LLT-0000) Public Version ML21196A1012021-07-15015 July 2021 Notification of an NRC Fire Protection Team Inspection (FPTI) (NRC Inspection Report 05000280/2021011 and 05000281/2021011) and Request for Information (RFI) ML21195A2442021-07-13013 July 2021 NRR E-mail Capture - Draft RAI Appendix E to Topical Report DOM-NAF-2 Qualification of the Framatome BWU-I CHF Correlation in the Dominion Energy VIPRE-D Computer Code ML21102A3122021-04-12012 April 2021 NRR E-mail Capture - Surry, Units 1 & 2 - Final RAI for the LOCA AST LAR ML21076A4622021-03-17017 March 2021 NRR E-mail Capture - Draft RAI for Versatile Internals and Component Program for Reactors Vipre Code Review (L-2021-LLT-0000) ML21061A0292021-03-0101 March 2021 2021 Sur - POV Inspection Information Request ML21049A2662021-02-16016 February 2021 NRR E-mail Capture - Surry, Units 1 and 2 - Final RAI Concerning the Leak-Before-Break (LBB) LAR ML21049A2672021-02-11011 February 2021 NRR E-mail Capture - Surry, Units 1 & 2 - Draft RAI for the LBB LAR ML21020A1322021-01-19019 January 2021 NRR E-mail Capture - RAIs for Surry'S Request for Proposed Alternative S1-I5-ISl-05 and S2-I5-ISl-06 (ML20296A680) ML21020A1332021-01-13013 January 2021 NRR E-mail Capture - Draft RAIs for Surry'S Request for Proposed Alternative S1-I5-ISl-05 and S2-I5-ISl-06 (ML20296A680) ML20315A3972020-11-10010 November 2020 Notification of NRC Supplemental Inspection (95001) and Request for Information - RA ML20156A0652020-06-0404 June 2020 NRR E-mail Capture - Final RAIs for Surry U1 Fall 2019 Sgtir Application ML20136A0102020-05-14014 May 2020 NRR E-mail Capture - Final RAIs Regarding Surry Units 1 & 2 LAR to Adopt 10 CFR 50.69 ML20134J1382020-05-0606 May 2020 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML20106E9552020-04-15015 April 2020 Program Inspection RFI ML20029D8382020-02-0505 February 2020 Email from T. Tran, Nmss/Drefs/Elrb; Re., Request for Additional Information - Surry SLRA Environmental Review ML20013C7282020-01-0909 January 2020 NRR E-mail Capture - Final RAI Regarding Surry'S TS One-Time 14-Day AOT RSST Cable Replacement LAR ML20007F7952020-01-0606 January 2020 NRR E-mail Capture - Surry RAI Regarding Its Rx Coolant P-T Limits LAR ML19323E2212019-11-13013 November 2019 NRR E-mail Capture - RAI on the SPS Rtb CT Extension LAR ML19317F1042019-11-0707 November 2019 NRR E-mail Capture - Draft RAIs for SB LOCA LAR (Non Prop) ML19296D8982019-10-23023 October 2019 NRR E-mail Capture - RAI for Surry ISTF-411 LAR to Extend Rx Trip Breakers TS CT to 24 Hours ML19283B6252019-10-0202 October 2019 Questions Related to Interval Visual Inspections in Lieu of External Visual Inspections ML19283B6232019-09-20020 September 2019 NRC Surry Draft RAI-Open Cycle Cooling Water (NRC TRP-20 James Gavula) ML19283B6282019-09-19019 September 2019 SLRA - Draft 3rd Round RAI - Selective Leaching (Trp 33) ML19283B6272019-09-18018 September 2019 SLRA - Clarification Call for 3rd Round RAI - Trp 14 (Buried Piping) ML19253C7532019-08-20020 August 2019 SLRA Transmittal Email Attachment 4D Confirmation Letter - August 20, 2019 ML19231A1532019-08-14014 August 2019 Final Requests for Additional Information for the Safety Review of the Surry Power Station, Units 1 and 2 Subsequent License Renewal Application Set 4 August 14, 2019. L-2018-RNW-0023/000951 ML19217A3582019-08-0202 August 2019 SLRA RAI Transmittal Email Set 3 with Attachments- 2-August 5, 2019 ML19192A2472019-07-10010 July 2019 Final Disposition List of Request for Additional Information for the Safety Review of the Surry Power Station, Units 1 and 2 Subsequent License Renewal Application (L-2018-RNW-0023/000951) ML19184A1392019-07-0101 July 2019 SLRA Email Transmittal of Draft RAIs with Attachments - 29JUN2019 ML19169A0962019-06-17017 June 2019 NRR E-mail Capture - Request for Additional Information Emergency Action Level Scheme Change for Millstone Power Station - Units 1, 2, and 3, North Anna Power Station - Units 1 and 2, and Surry Power Station - Units 1 and 2 ML19164A3332019-06-11011 June 2019 Final Request for Additional Information for the Safety Review of the Surry Power Station, Units 1 and 2 Subsequent License Renewal Application Set 2 June 11, 2019 ML19176A5262019-06-11011 June 2019 SLRA Email Transmittal of Draft RAIs with Attachments June 11, 2019 ML19163A0182019-06-11011 June 2019 Transmittal Email Surry SLRA Draft RAI- 22 May 2019 ML19163A3962019-06-11011 June 2019 SLRA Email Transmittal of Draft RAIs with Attachments - June 11, 2019 2023-07-06
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From: Sayoc, Emmanuel To: Paul Aitken; Eric A Blocher Cc: Wu, Angela
Subject:
Draft RAI Surry TRP 20 Open Cycle Cooling Water Date: Tuesday, June 11, 2019 10:23:00 AM Attachments: 020 Surry OCCW RAI Gavula Johnson.docx Paul, Eric, I am hoping this is the last RAI. Do you need a clarification call?
Emmanuel Manny Sayoc Safety Project Manager NRR/DLR 301-415-4084
Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As provided in §54.29(a), a renewed license may be issued if the staff finds that actions have been identified, which either have been or will be taken, with respect to managing the effects of aging during the period of extended operation.
As described in the Standard Review Plan for Subsequent License Renewal (SLR), an applicant may reference the GALL-SLR Report in a subsequent license renewal application (SLRA) to designate which aging management programs will be used and how they correspond to the programs in the GALL-SLR Report. If an applicant takes credit for a program in the GALL-SLR Report, it is incumbent on the applicant to ensure the conditions and operating experience at the plant are bounded by those for which the GALL-SLR Report aging management program (AMP) was evaluated. To complete its review and enable the formulation of a finding under §54.29(a),
the staff requires additional information regarding the matters described below.
RAI B2.1.11-1 Generic Letter 89-13 Commitments Background. GALL-SLR AMP XI.M20, Open-Cycle Cooling Water System, states that the inspection scope, methods, and frequencies are in accordance with the applicants docketed response to Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Components. SLRA Section B2.1.11, Open-Cycle Cooling Water System, states that the program is an existing program that, following enhancement, will be consistent with the GALL-SLR AMP XI.M20. SLRA Section B2.1.11 also states that periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers is performed in accordance with the site commitments to GL 89-13.
ETE-SLR-2018-1314, Aging Management Program Evaluation Report - Open-Cycle Cooling Water System, Revision 2, documents and evaluates the activities in the associated AMP that are credited for managing aging as part of Surrys SLRA. ETE-SLR-2018-1314 discusses a discrepancy between Surrys response to GL 89-13 (letter dated October 2, 1991 (89-572G))
and the maintenance strategy implementation for the charging pump lube oil coolers. The maintenance strategy changed from periodic replacement of charging pump lube oil coolers to performing routine inspection and maintenance. ETE-SLR-2018-1314 states that the discrepancy was evaluated in accordance with the commitment change evaluation process and cites corrective action CA3022000 Submit Commitment Change Paperwork to Update Requirements for Charging Pump LO [Lube Oil] Coolers (March 9, 2017). The staff noted that the change in maintenance strategy affected the scope of Surrys Open-Cycle Cooling Water System program, because components that are periodically replaced are excluded from the scope of an aging management review for license renewal.
In response to staff questions for CA3022000, Surry posted condition report CR1091365, (March 6, 2018) A Commitment Change Evaluation Was Completed and Approved Mistakenly.
The condition report states that the commitment change evaluation was for a change made to a response to the NRC, not a commitment to the NRC. The actions discussed in the condition report included a clarification regarding the difference between a response and a commitment to the NRC.
During its review of ER-SU-5314, Generic Letter 89-13 Program, Revision 2, the staff noted that Attachment 1, Generic Letter 89-13 Components and Commitments, includes a table for each set of components in the program and includes a column labeled Commitment Source.
Every set of components in the list includes Letter to NRC 10/2/91 Serial Number 89-572G as
the source of the commitment to perform the specified GL 89-13 activity. However, the tables initial note states that the letter dated April 30, 1991 (Serial 89-572E), summarized the GL 89-13 program and that the response was updated by letter dated October 2, 1991 (Serial 89-572G),
which supersedes Serial Number 89-572E. No new commitments were made.
The staff notes that the letter dated April 30, 1991 (Serial 89-572E), states that a detailed revision of [Surrys] initial January 29, 1990, response incorporating the subsequent supplements and the additions integrated into this summary description will be separately forwarded. In addition, the staff notes that none of the GL 89-13 response letters appear to specifically identify the sites activities for periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers as being commitments.
Issue. Because none of the sites GL 89-13 response letters appear to specifically identify the commitments for periodic heat transfer testing, visual inspection, and cleaning of safety-related heat exchangers, the staff was unable to verify that the Open-Cycle Cooling Water System program would be performed in accordance with the sites commitments to GL 89-13. The program documentation appears to cite the letter dated October 2, 1991 (89-572G), as the source of the sites GL 89-13 commitments. However, the recent condition report (CR1091365) states that because the information in the October 2, 1991, letter was only a response to GL 89-13 and not a commitment, there was no need to perform a commitment change evaluation for changing the approach discussed in the October 2, 1991, letter. Based on the position discussed in CR1091365, the staff is unsure of the sites GL 89-13 commitments.
Request. Provide additional information to clarify the sites GL 89-13 commitments. Include information about which prior GL 89-13 response letter(s) to the NRC contain(s) the commitments that are discussed in SLRA Section B2.1.11. If the source of Surrys commitments to GL 89-13 are not from the response dated October 2, 1991 (89-572G), also include information regarding the circumstances about why ER-SU-5314, Generic Letter 89-13 Program, Revision 2, cites the letter dated October 2, 1991 (89-572G).
RAI B2.1.11-2 AMR Items for Open-Cycle Cooling Water System Background. SLRA Section B2.1.11, Open-Cycle Cooling Water System, states that periodic heat transfer testing, visual inspection, and cleaning of heat exchangers are performed in accordance with the site commitments to GL 89-13 to verify heat transfer capabilities. SLRA Section B2.1.11 also includes an enhancement to the monitoring and trending program element to revise procedures to require trending the inspection results of the emergency service water pump engine heat exchangers.
The staff notes that ER-SU-5314, Generic Letter 89-13 Program, Revision 2, includes the emergency service water pump engine heat exchanger and specifies associated activities for periodic heat transfer testing, as well as inspection and maintenance. In addition, ER-SU-5314 includes the emergency service water pump angle drive and specifies that heat transfer is checked during monthly surveillance testing, and that cooling water flow is verified during inspection and maintenance activities.
Although SLRA Table 3.3.2-4 Service Water - Aging Management Evaluation, includes other emergency service water pump components, it does not appear to include the emergency service water pump engine heat exchanger or the emergency service water pump angle drive.
Issue. Although SLRA Section B2.1.11 includes an enhancement to trend inspection results associated with emergency service water pump engine heat exchangers, the SLRA does not appear to include a corresponding aging management review item(s). In addition, although Surrys GL 89-13 program appears to specify activities to address heat transfer for the emergency service water pump angle drive, the SLRA does not appear to include a corresponding aging management review item.
Request. For the emergency service water pump engine heat exchangers and the emergency service water pump angle drives, provide information showing that assessment of the heat transfer capabilities of safety-related heat exchangers (with a heat transfer intended function) will be performed by the SLRA Section B2.1.11, Open-Cycle Cooling Water System program, in accordance with site commitments to GL 89-13. Include information showing either 1) that existing aging management review items with corresponding aging effects are included in the SLRA for these components or 2) that aging management review items are not needed for these components, to demonstrate that the effects of aging will be adequately managed.