ML19098A810

On-Site Regulatory Audit Regarding the Subsequent License Renewal Application Review (EPID Nos. L-2018-RNW-0023 and L-2018-RNW-0024)

ML19098A810
Person / Time
Site:	Surry
Issue date:	04/17/2019
From:	Sayoc E NRC/NRR/DMLR/MRPB
To:	Stoddard D - No Known Affiliation
Sayoc E, NRR-DMLR 415-4084
References
EPID L-2018-RNW-0023, EPID L-2018-RNW-0024
Download: ML19098A810 (9)

Text

April 17, 2019 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd Glen Allen, VA 23060-6711

SUBJECT:

SURRY POWER STATION, UNIT NOS. 1 AND 2 ON-SITE REGULATORY AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NOS. L-2018-RNW-0023 AND L-2018-RNW-0024)

Dear Mr. Stoddard,

By letter dated October 15, 2018 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18291A842), as supplemented by letter dated January 29, 2019 (ADAMS Package Accession No. ML18291A842), and by letter dated April 2, 2019 (ADAMS Package Accession No. ML19095A666), the Virginia Electric and Power Company (Dominion Energy Virginia or Dominion) submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Renewed Facility Operating License Nos. DPR-32 and DPR-37 for the Surry Power Station, Unit Nos. 1 and 2 (SPS). Dominion requested renewal of the SPS operating licenses for an additional 20 years beyond the current renewed 60-year current license terms, which expire on May 25, 2032, for Unit 1 and January 29, 2033, for Unit 2. The staff is reviewing this application in accordance with the guidance in NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants.

The NRC staff plans to conduct an on-site regulatory audit at SPS facility from April 22-26, 2019, in accordance with the enclosed regulatory audit plan. If you have any questions, please contact me at 301-415-4084 or at Emmanuel.Sayoc@nrc.gov.

Sincerely,

/RA/

Emmanuel Sayoc, Project Manager License Renewal Project Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281

Enclosure:

Regulatory Audit Plan

ML19098A810 *concurred by email OFFICE PM:MRPB:DMLR LA:MRPB:DMLR PM:MRPB:DMLR* BC:MRPB:DMLR*

NAME ESayoc YEdmonds AWu EOesterle DATE 4/11/2019 4/11/2019 4/9/2019 4/11/2019 OFFICE PM:MRPB:DMLR NAME ESayoc DATE 4/17/2019

Audit Plan On Site Regulatory Audit Regarding the Surry Power Station, Unit Nos. 1 and 2 Subsequent License Renewal Application April 22-26, 2019 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure

Plan for the Scoping and Screening Methodology Audit Regarding the Surry Power Station, Unit Nos. 1 and 2 Subsequent License Renewal Application

1. Background By letter dated October 15, 2018 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18291A842), as supplemented by letter dated January 29, 2019 (ADAMS Package Accession No. ML18291A842), and by letter dated April 2, 2019 (ADAMS Package Accession No. ML19095A666), the Virginia Electric and Power Company (Dominion Energy Virginia or Dominion) submitted an application for subsequent license renewal of Renewed Facility Operating License Nos.

DPR-32 and DPR-37 for the Surry Power Station, Unit Nos. 1 and 2 (SPS) to the U.S.

Nuclear Regulatory Commission (NRC) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and Part 54 of Title 10 of the Code of Federal Regulations, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.

2. Regulatory Audit Base License renewal requirements are specified in Title 10 of the Code of Federal Regulations (10 CFR), Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Guidance is provided in NUREG-2192, Rev. 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR), dated July 2017, and NUREG-2191, Rev. 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, dated July 2017.

3. Regulatory Audit Scope This regulatory audit is scheduled for April 22-26, 2019, and is a follow-up from the in-office regulatory audit which was conducted between February 4 - 28, 2019. The scope of this audit focuses on areas where the NRC staff needs to observe, walkdown, and verify site information to complete its review of specific aging management programs (AMP), aging management review (AMR) line items, time limited aging analyses (TLAA),

and the scoping results of systems, structures and components (SSCs). The specific areas of focus are provided below.

3.1 SLRA AMP B.2.1.17 Outdoor and Large Atmospheric Metallic Storage Tanks The staff plans to conduct this portion of the Audit at SPS on April 24-25, 2019.

Document Review:

• Review inspection results of Fire Water System Storage Tanks (FWST) wall thickness (floor and sides) measurements conducted in March 2019.

• Review results of engineering analyses related to the FWST wall thickness measurements conducted in March 2019.

• Review recent fire water pump flow testing results with applicant.

Break Out Sessions:

• Meet with Dominion staff to discuss results of FWST inspections, engineering analyses, and potential proposed changes to how loss of material will be managed for the FWST in the Subsequent Period Extended Operation.

• Discuss fire water pump testing results in regard to the trend of decreased performance.

Walkdowns:

Staff would like to conduct walkdowns of the following tanks to observe for loss of material; conditions at the tank-to-concrete interface; and when insulation is installed on the tank, condition of insulation:

• Refueling Water Storage Tanks

• Refueling Water Chemical Addition Tanks

• Emergency Condensate Storage Tanks

• Emergency Condensate Makeup Tanks

• Fire Protection/Domestic Water Storage Tanks 3.2 SLRA AMP B.2.1.30, ASME Section XI, Subsection IWL The staff plans to conduct this portion of the Audit at SPS on April 22-23, 2019.

Document Review:

• Review documentation related to wood/organic materials found in containment concrete including extent of condition reports, inspection reports, engineering analyses, work orders, corrective action reports, and changes/updates to ASME Section XI, Subsection IWL aging management program in order to identifying potential effects of aging or degradation causing a loss of intended function during the SPEO

• Provide demonstration of implementation tools/databases Break Out Sessions:

Meet with Dominion staff to discuss documents above Walkdowns:

Walkdown of the exterior of the containment structures with site personnel to discuss containment repairs.

3.3 SLRA AMP B.2.1.31, ASME Section XI, Subsection IWF The staff plans to conduct this portion of the Audit at SPS on April 22-23, 2019.

Document Review:

Review Reactor Pressure Vessel (RPV) Structural (Class 1) support drawings and their assemblies (11448-FM-37D, 109A, 109B; 11448 FV-7 Series (A-P as applicable),

11448-FC-16A, 16C, 16D, 16E), specifications (NUS 96 and NUS 368 and other relevant specifications.

Break Out Sessions:

Meet with Dominion staff to clarify and resolve questions on RPV structural (Class 1) support drawings and their assemblies and to discuss associated potential aging effects issues on lubricants and sliding surfaces.

Walkdowns: None 3.4 Irradiation Effects on Concrete & Steel The staff plans to conduct this portion of the Audit at Dominion Headquarters, Innsbrook VA, on April 23-26, 2019.

Background:

Dominions Subsequent License Renewal Application (SLRA) Section 3.5.2.2.2.6, as supplemented by letter dated January 29, 2019, discusses its Further Evaluation of the aging effects of irradiation on the Concrete Biological Shield (or Primary Shield Wall) and the Reactor Vessel (RV) Support Steel Assembly. The SLRA states that no plant-specific AMP to manage the effects of irradiation is required. To verify this claim, staff from the Office of Nuclear Reactor Regulation will conduct a technical issue regulatory audit on irradiation aging effects on the applicable concrete and structural steel components to: (1) gain a better understanding of the applicants technical evaluation and disposition of adequacy; and (2) review documentation of technical bases supporting the conclusion that a plant-specific program is not necessary to manage the irradiation aging effects for concrete and structural steel.

Regulatory Audit Scope:

The purpose of the audit is for the staff to verify that in accordance with 10 CFR 54.21(a)(3), that the applicant has demonstrated the aging effects of irradiation on the concrete primary shield wall and the RV steel supports (namely, the neutron shield tank (NST) and sliding feet assemblies and surfaces) will be adequately managed so that the intended functions will be maintained consistent with the Current Licensing Basis for the subsequent period of extended operation. The scope of this audit is to examine the applicants supporting documentation for its disposition of the Further Evaluation provided in SLRA Section 3.5.2.2.2.6, as supplemented on January 29, 2019. Staff guidance in SRP-SLR Section 3.5.2.2.2.6, Reduction of Strength and Mechanical Properties of Concrete Due to Irradiation, states in part:

Further evaluation is recommended of a plant-specific program to manage aging effects of irradiation if the estimated (calculated) fluence

levels or irradiation dose received by any portion of the concrete from neutron (fluence cutoff energy E > 0.1 MeV) or gamma radiation exceeds the respective threshold level during the subsequent period of extended operation or if plant-specific OE of concrete irradiation degradation exists that may impact intended functions.

For structural steel, the irradiation aging effects to be addressed pursuant to 10 CFR 54.21(a)(3) is the loss of fracture toughness and related reduction in strength due to neutron irradiation embrittlement. The applicant has included its evaluation of this aging effect also as part of the supplemented SLRA Section 3.5.2.2.2.6.

The SLRA Section 3.5.2.2.2.6, as supplemented, discusses evaluations and references technical reports in support of: (1) its determination of projected fluence to 80 years of operation, and for concrete comparison against the applicable threshold criteria in SRP-SLR, (2) a fracture mechanics evaluation of the RV support steel assembly, and (3) conclusion that a plant-specific program is not necessary for both the concrete and the structural steel. The applicant determined that concrete biological shield wall and RV steel support assembly (components as determined above) at Surry would remain capable of performing its intended functions through the subsequent period of extended operation without being managed for this aging effect.

During this audit, the staff will use the following scope as a guide:

• Examine the applicants CLB documents, drawings, specifications and related references to verify the configuration and materials that make the concrete primary shield wall and RV support structural steel components (including the NST and sliding foot assemblies) and their connections and assess similarity of the two units.

• Review supporting calculations and evaluations, including those related to estimated levels of irradiation exposure on affected structural components (concrete and steel),

imposed design loads and stresses, and fracture mechanics evaluations for structural steel including their effects on weldments, bolts, and lubricants.

• Interview applicant representatives to obtain additional clarification related to the disposition of the irradiation effects on affected containment concrete, and steel structures and components as noted above.

• Assess whether it needs additional information to be submitted to the NRC (docketed) in support of this review.

Agenda:

• Review of analyses to estimate neutron fluence and gamma radiation and thermal heating (as applicable) levels incident at the RV support (NST and sliding foot assemblies and components) and its attenuation to the CBS wall; also consideration of complete neutron energy spectrum for embrittlement predictions.

• Review of CLB design loading combinations including design basis events such as LOCA and SSE for the RV Support structure.

• Consideration of the impact of observed or potential degradations (such as corrosion, degradation of lubricants, etc.) through the end of the SPEO on the

fracture mechanics and structural evaluations for irradiation effects on the RV Support Assembly (NST, sliding foot assemblies and components).

• Rationale for assumptions in the evaluations related to the irradiation aging effects on structural steel and concrete.

Document Review:

For the irradiation effects technical issue regulatory audit, the audit team will review the SLRA, as supplemented and revised, the bases documents and other Dominion supporting documents as appropriate and requests the following:

• a presentation to the staff that systematically explains the methodology (including assumptions) and references used.

• one hard copy of: (i) relevant materials (including technical reports, original design calculations and subsequent modifications, including those applicable to SLRA) be available to the staff in addition to electronic files; (ii) all associated drawings and details (design and as-built) and construction/fabrication specifications for applicable structures (i.e., NST, sliding foot assemblies and components, CBS wall, lubricants used), including drawings identifying: dimensions, distances, anchorage of reactor pressure vessel and nozzles to supports, materials used, etc.)

Break Out Sessions:

• Applicant demonstration (presentation) of methodology; identification and specifics of the use of applicable references, technical reports (including EPRI reports), analysis, and process and criteria used to justify its disposition of the aging effects of irradiation on concrete and steel structures in the vicinity of the reactor vessel; clarify similarity of the two units for the irradiation effects assessment.

• Follow-up discussion on in-office audit questions that are not dispositioned.

• Determine information that will need to be submitted on the docket subsequent to the audit for continued review of the SLRA.

Walkdowns: None 3.5 B3.3 Environmental Qualification (EQ) of Electric Equipment, SLRA TLAA Section 4.3, Environmental Qualification of Electric Equipment The staff plans to conduct this portion of the Audit at SPS on April 23, 2019.

NUREG 0588 states that equipment interfaces for electrical equipment should be included in qualification process. Thus, the equipment that should be qualified includes gaskets, seals, lubricants, terminations, and other mechanical equipment. Staff would like to understand the rationale for excluding mechanical equipment from the EQ master list and also understand how the SLRA addresses the aging effects of the interfaces of electrical equipment to ensure safety function performance will be maintained throughout the period of subsequent license renewal.

Document Review:

• Observe and verify site information on any maintenance or inspection activities on EQ equipment (if in progress at the time of the audit).

• Review site Information on EQ master list, EQ test reports for equipment.

Break Out Sessions:

Interview site system engineers and subject matter experts on EQ regarding the scope of equipment included in the EQ master list.

Walkdowns: None

4. Team Assignments and Schedule Team members and assignments are as follows:

Name Area Brian Wittick, Branch Chief Management Oversight Emmanuel Sayoc, Project Manager Project Management William Holston, Senior Mechanical Engineer Fire Water System Alan Huynh, Mechanical Engineer Fire Water System George Thomas, Structural Engineer Irradiation Effects on Concrete & Steel Angela Buford, Structural Engineer ASME Section XI, Subsection IWL and IWF Andrew Prinaris, Structural Engineer ASME Section XI, Subsection IWL and IWF, Irradiation Effects on Concrete & Steel Bill Rogers, Senior Reactor Engineer Irradiation Effects on Concrete & Steel, Project Management Sheila Ray, Electrical Engineer Environmental Qualification of Electric Equipment Matthew McConnell Environmental Qualification of Electric Equipment

5. Logistics The audit will be conducted on-site at Surry Power Station Units 1 and 2, and Dominion Headquarters, Innsbrook VA, during the week of April 22-26, 2019, as described above.

Entrance and exit briefings will be held at the beginning and end of the audit, respectively. Working hours are from 8 a.m. to 4:30 p.m. Status briefs will occur as deemed necessary during the audit.

6. Special Requests The NRC staff requests the following:

• a suitable dedicated facility for the audit team, outside of the protected area, to gather during the audit and to hold meetings between NRC team members and applicant personnel. The facility should have speaker phones available for conference calls with the NRC staff who may be supporting the audit from NRC HQs.

• to facilitate the audit, reviews, maintain focus and minimize distractions, the irradiation effects audit team requests a separate room, also outside of the protected area, from other NRC SLRA-related on-site auditors.

• availability of presentation equipment or materials (e.g., projector) to facilitate information exchange to the entire group (when such exchange is necessary)

• availability of cognizant technical staff (including contractors as necessary) for interview

• internet access (not necessarily to allow access to Dominion internal sites)

7. Deliverables An audit report should be issued to the applicant within 90 days from the end of the audit.