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| Line 22: |
Line 22: |
| SUBSEQUENT LICENSE RENEWAL APPLICATION (SLRA) | | SUBSEQUENT LICENSE RENEWAL APPLICATION (SLRA) |
| REQUESTS FOR ADDITIONAL INFORMATION (RAIS) | | REQUESTS FOR ADDITIONAL INFORMATION (RAIS) |
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| SAFETY - SET 5 | | SAFETY - SET 5 |
| : 1. Buried and Underground Piping and Tanks, AMP XI.M41 Regulatory Basis: Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(3) requires an applicant to demonstrate that, for components within the scope of license renewal, the effects of aging will be adequately managed to maintain the components intended function(s) consistent with the current licensing basis for the period of extended operation. One of the findings that the Nuclear Regulatory Commission (NRC) staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. To complete its review and enable formulation of a finding under 10 CFR 54.29(a), the staff is requesting additional information regarding the matters described below. | | : 1. Buried and Underground Piping and Tanks, AMP XI.M41 |
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| | Regulatory Basis: Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(3) requires an applicant to demonstrate that, for components withi n the scope of license renewal, the effects of aging will be adequately managed to maintain the components intended function(s) consistent with the current licensing basis for the period of extended operation. One of the findings that the Nuclear Regulatory Commission (NRC) st aff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been ide ntified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of components that have been identified to re quire review under 10 CFR 54.21, such that there is reasonable assurance that the activities aut horized by the renewed license will continue to be conducted in accordance with the current li censing basis. To complete its review and enable formulation of a finding under 10 CFR 54.29(a ), the staff is requesting additional information regarding the matters described below. |
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| ==Background:== | | ==Background:== |
| As required by 10 CFR 54.21(d), each [subsequent] license renewal application (SLRA) must include a final safety analysis report (FSAR) supplement containing a summary description of the programs and activities determined by 10 CFR 54.21(a) for managing the effects of aging. In its discussions about FSAR supplements, NRC Standard Review Plan for Subsequent License Renewal (SRP-SLR), Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, (NUREG-2192, Revision 0, July 2017) | | As required by 10 CFR 54.21(d), each [subsequent] license renewal application (SLRA) must include a final safety analysis report (FSAR) suppl ement containing a summary description of the programs and activities determined by 10 CFR 54.21(a) for managing the effects of aging. In its discussions about FSAR supplements, N RC Standard Review Plan for Subsequent License Renewal (SRP-SLR), Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, (NUREG-2192, Revision 0, July 2017) |
| (ADAMS Accession No. ML17187A204) Section 3.3.2.5 notes that the FSAR supplement description should be sufficiently comprehensive such that later changes to the program can be controlled by 10 CFR 50.59 Changes, Tests, and Experiments. The SRP-SLR also notes that the program description should include any future aging management activities including enhancements and commitments and contain the bases for determining that aging effects will be managed. The SRP-SLR further notes that the type of information to be included is provided in NUREG-2191, Revision 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, dated July 2017 (ADAMS Accession No. ML17187A031), | | (ADAMS Accession No. ML17187A204) Section 3.3.2.5 notes that t he FSAR supplement description should be sufficiently comprehensive such that late r changes to the program can be controlled by 10 CFR 50.59 Changes, Tests, and Experiments. The SRP-SLR also notes that the program description should include any future aging managem ent activities including enhancements and commitments and contain the bases for determin ing that aging effects will be managed. The SRP-SLR further notes that the type of informa tion to be included is provided in NUREG-2191, Revision 0, Generic Aging Lessons Learned for S ubsequent License Renewal (GALL-SLR) Report, dated July 2017 (ADAMS Accession No. ML17187A031), |
| Table XI-01, FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs [AMP]. | | Table XI-01, FSAR Supplement Summaries for GALL-SLR Report Cha pter XI Aging Management Programs [AMP]. |
| As amended by Supplement 4 to the SLRA ({{letter dated|date=August 26, 2021|text=letter dated August 26, 2021}}, ADAMS Accession No. ML21238A297), Dominion Energy included extensive changes to the program description in SLRA Section B2.1.27, Buried and Underground Piping and Tanks. Supplement 4 adds a new Enhancement (No. 6) to reflect the deletion of jockey pump monitoring as the basis for not performing excavated direct visual inspection of the buried gray cast iron fire main piping. The new enhancement describes the performance of nondestructive examinations (i.e., magnetic particle and radiographic testing) of the excavated piping, and destructive examinations of any identified bounding cracks, with engineering evaluations of crack growth, and flaw stability to address cracking due to cyclic loading. Supplement 4 also modifies Enhancement No. 5 to the Buried and Underground Piping and Tanks program to provide for destructive examinations of the excavated gray cast iron pipe as given in GALL-SLR AMP XI.M33, Selective Leaching. | | |
| | As amended by Supplement 4 to the SLRA ({{letter dated|date=August 26, 2021|text=letter dated August 26, 2021}}, ADAMS Accession No. ML21238A297), Dominion Energy included extensive changes to the program description in SLRA Section B2.1.27, Buried and Underground Piping and Tanks. Supplement 4 adds a new Enhancement (No. 6) to reflect the deletion of jockey pump moni toring as the basis for not performing excavated direct visual inspection of the buried gra y cast iron fire main piping. The new enhancement describes the performance of nondestructive exa minations (i.e., magnetic particle and radiographic testing) of the excavated piping, and destructive examinations of any identified bounding cracks, with engineering evaluations of cra ck growth, and flaw stability to address cracking due to cyclic loading. Supplement 4 also modi fies Enhancement No. 5 to the Buried and Underground Piping and Tanks program to provide for destructive examinations of the excavated gray cast iron pipe as given in GALL-SLR AMP XI.M 33, Selective Leaching. |
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| | Supplement 4 to the application also modified SLRA Section A1, Summary Description of Aging Management Programs, and SLRA Section A1.27, Buried an d Underground Piping and Tanks, by adding the sentence: The program will also manage cracking due to cyclic loading in buried gray cast iron fire protection piping that is lined w ith a cementitious coating. A previous supplement had deleted the discussion about monitoring jockey pump activity in lieu of performing visual inspections of buried fire protection system components. The staff notes that Supplement 4 also modified SLRA Table A4.0-1, Subsequent Licen se Renewal Commitments, Item 27 to describe the commitments to revise procedures for En hancements No. 5 and No.6. |
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| | As documented in the NRCs Determination of Acceptability and S ufficiency for Docketing associated with the SLRA ({{letter dated|date=October 13, 2020|text=letter dated October 13, 2020}}, ADAMS Accession No. ML20258A284), the GALL-SLR Report does not address cracking due to cyclic loading for buried gray cast iron piping. Dominion recognized this aspect when it eventually cited an aging management review item with generic note H (indicating the agin g affect was not in the GALL-SLR Report) for cracking due to cyclic loading that will b e managed by the Buried and Underground Piping and Tanks program. |
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| | Because the aging effect for the given material and environment combination is not addressed in the GALL-SLR Report, the FSAR program description in GALL-SL R Table XI-01 for the Buried and Underground Piping and Tanks AMP would not be suffic ient. The staff notes that the SLRA did not initially address cracking due to cyclic loadi ng and after substantially enhancing the Buried and Underground Piping and Tank program on ly a single sentence (noted above) was added to the FSAR program description. The staff al so notes that although the table with subsequent license renewal commitments includes a de scription of the programs enhancements, once commitments (e.g., to revise procedures) hav e been completed, they can, and have been deleted from the commitment table. |
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| | RAI 4.7.6-1 |
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| | Issue: In order to ensure that changes to the program, which c ould decrease the overall effectiveness of the program to manage the effects of aging, wi ll receive appropriate review by a licensee, the FSAR supplement s hould be sufficiently comprehens ive. The FSAR supplement in SLRA Section A1.27, Buried and Underground Piping and Tanks, appears to lack a sufficient description of the activities for managing cracking due to cyclic loading to provide appropriate administrative and regulatory controls for the prog ram. The current program includes specific nondestructive and destructive inspections of excavated gray cast iron piping and relatively unique engineering evaluations of crack growth a nd flaw stability in a brittle material that are not described in the current FSAR supplement. In addition, specific activities for managing the loss of material due to selective leaching are being performed as part of the Buried and Underground Piping and Tanks program; however, these activities are not referenced or otherwise noted in SLRA Section A1.21, Selective Leaching. The staff cannot complete its review of the above FSAR supplements without addit ional information. |
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| Supplement 4 to the application also modified SLRA Section A1, Summary Description of Aging Management Programs, and SLRA Section A1.27, Buried and Underground Piping and Tanks, by adding the sentence: The program will also manage cracking due to cyclic loading in buried gray cast iron fire protection piping that is lined with a cementitious coating. A previous supplement had deleted the discussion about monitoring jockey pump activity in lieu of performing visual inspections of buried fire protection system components. The staff notes that Supplement 4 also modified SLRA Table A4.0-1, Subsequent License Renewal Commitments, Item 27 to describe the commitments to revise procedures for Enhancements No. 5 and No.6.
| | Request: Provide additional information that either: (a) expl ains how the current FSAR supplement descriptions in SLRA Section A1.27 for of the Buried and Underground Piping and Tanks program and SLRA Section A1.21 for the Selective Leaching program will provide appropriate administrative and regulatory controls to ensure th at any future changes to the programs will not decrease their overall effectiveness to manag e the effects of aging, or (b) modifies the associated FSAR supplements to include a more detailed description of the programs and aging management activities.}} |
| As documented in the NRCs Determination of Acceptability and Sufficiency for Docketing associated with the SLRA ({{letter dated|date=October 13, 2020|text=letter dated October 13, 2020}}, ADAMS Accession No. ML20258A284), the GALL-SLR Report does not address cracking due to cyclic loading for buried gray cast iron piping. Dominion recognized this aspect when it eventually cited an aging management review item with generic note H (indicating the aging affect was not in the GALL-SLR Report) for cracking due to cyclic loading that will be managed by the Buried and Underground Piping and Tanks program.
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| Because the aging effect for the given material and environment combination is not addressed in the GALL-SLR Report, the FSAR program description in GALL-SLR Table XI-01 for the Buried and Underground Piping and Tanks AMP would not be sufficient. The staff notes that the SLRA did not initially address cracking due to cyclic loading and after substantially enhancing the Buried and Underground Piping and Tank program only a single sentence (noted above) was added to the FSAR program description. The staff also notes that although the table with subsequent license renewal commitments includes a description of the programs enhancements, once commitments (e.g., to revise procedures) have been completed, they can, and have been deleted from the commitment table.
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| RAI 4.7.6-1 Issue: In order to ensure that changes to the program, which could decrease the overall effectiveness of the program to manage the effects of aging, will receive appropriate review by a licensee, the FSAR supplement should be sufficiently comprehensive. The FSAR supplement in SLRA Section A1.27, Buried and Underground Piping and Tanks, appears to lack a sufficient description of the activities for managing cracking due to cyclic loading to provide appropriate administrative and regulatory controls for the program. The current program includes specific nondestructive and destructive inspections of excavated gray cast iron piping and relatively unique engineering evaluations of crack growth and flaw stability in a brittle material that are not described in the current FSAR supplement. In addition, specific activities for managing the loss of material due to selective leaching are being performed as part of the Buried and Underground Piping and Tanks program; however, these activities are not referenced or otherwise noted in SLRA Section A1.21, Selective Leaching. The staff cannot complete its review of the above FSAR supplements without additional information.
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| Request: Provide additional information that either: (a) explains how the current FSAR supplement descriptions in SLRA Section A1.27 for of the Buried and Underground Piping and Tanks program and SLRA Section A1.21 for the Selective Leaching program will provide appropriate administrative and regulatory controls to ensure that any future changes to the programs will not decrease their overall effectiveness to manage the effects of aging, or (b) modifies the associated FSAR supplements to include a more detailed description of the programs and aging management activities.}} | |
Letter Sequence RAI |
|---|
|
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance...
- Supplement, Supplement, Supplement, Supplement, Supplement
Results
Other: ML20258A284, ML20269A465, ML20276A192, ML20303A199, ML21036A060, ML21067A504, ML21067A507, ML21084A182, ML21091A004, ML21097A027, ML21145A217, ML21217A187, ML21239A064, ML21239A066, ML21239A068, ML21256A067, ML21256A069, ML21312A002, ML21312A003, ML21312A007, PMNS20211071, Discussion Between NRC and Dominion Regarding the North Anna Subsequent License Renewal - Safety Issue - Cyclic Fatigue, PMNS20211128, Discussion Between NRC and Dominion Regarding the North Anna Subsequent License Renewal - an Inconsistency in Documentation Regarding Reactor Coolant Pump Code Case N 481, TLAA 4.7.6
|
MONTHYEARML20140A3362020-05-18018 May 2020
Revised Reactor Vessel Materials Surveillance Capsule Withdrawal Schedules - Response to Request for Additional Information
Project stage: Response to RAI
ML20246G6972020-08-24024 August 2020
Application for Subsequent Renewed Operating Licenses
Project stage: Request
ML20246G7062020-08-24024 August 2020
Enclosure 4: Attachment 1 - PWROG-18005-NP, Revision 2, Determination of Unirradiated Rt and Upper-Shelf Values of the North Anna Units 1 and 2 Reactor Vessel Materials
Project stage: Request
ML20269A4652020-10-0606 October 2020
SLRA - Portal Letter
Project stage: Other
ML20276A1922020-10-0909 October 2020
Subsequent License Renewal Aging Management Audit Plan
Project stage: Other
ML20258A2842020-10-13013 October 2020
SLRA - Acceptance and Opportunity for Hearing Letter
Project stage: Other
ML20303A1992020-10-29029 October 2020
Subsequent License Renewal Safety Project Management Assignment
Project stage: Other
ML21035A3032021-02-0404 February 2021
(Naps), Units 1 and 2 - Update to Subsequent License Renewal Application (SLRA) Supplement 1
Project stage: Supplement
ML21063A5522021-03-0404 March 2021
Final Request for Additional Information Set 1 - North Anna SLRA Safety Review (EPID L-2020-SLR-0000) - Email
Project stage: RAI
ML21063A5602021-03-0404 March 2021
Final Request for Additional Information Set 1 - North Anna SLRA Safety Review (EPID L-2020-SLR-0000) - Enclosure
Project stage: RAI
ML21067A5042021-03-0808 March 2021
Final Request for Confirmation of Information (RCI) Set 1 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Email
Project stage: Other
ML21067A5072021-03-0808 March 2021
Final Request for Confirmation of Information (RCI) Set 1 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure
Project stage: Other
ML21076B0252021-03-17017 March 2021
Update to Subsequent License Renewal Application, Supplement 2
Project stage: Supplement
ML21084A1822021-03-24024 March 2021
Subsequent License Renewal Application Response to NRC Requests for Confirmation of Information for the Safety Review - Set 1
Project stage: Other
ML21091A1872021-04-0101 April 2021
Response to NRC Request for Additional Information Regarding Safety Review - Set 1 & Clarification to Aging Management of Fire Protection System Lined Ductile Iron Valves
Project stage: Supplement
ML21091A0022021-04-0101 April 2021
Final Request for Additional Information Set 2 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Email
Project stage: RAI
ML21091A0032021-04-0101 April 2021
Final Request for Additional Information Set 2 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure 1 - RAIs
Project stage: RAI
ML21091A0042021-04-0101 April 2021
SLRA Safety Review - Withdrawn Requests for Information (EPID No. L-2020-SLR-0000) - Enclosure 2
Project stage: Other
ML21036A0602021-04-0808 April 2021
Report for the Aging Management Audit Regarding the Subsequent License Renewal Application Review
Project stage: Other
ML21097A0272021-04-14014 April 2021
Request for Withholding from Public Disclosure Regarding Subsequent License Renewal Application
Project stage: Other
ML21104A0372021-04-15015 April 2021
Request for Withholding Information Regarding Subsequent License Renewal Application
Project stage: Withholding Request Acceptance
ML21119A2872021-04-29029 April 2021
(Naps), Unit 1 and 2 - Subsequent License Renewal Application (SLRA) Response to NRC Request for Additional Information Safety Review - Set 2 and Flow Accelerated Corrosion Program Enhancement Completion
Project stage: Response to RAI
ML21123A2982021-05-0303 May 2021
Final Request for Additional Information Set 3 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure
Project stage: RAI
ML21123A2972021-05-0303 May 2021
Final Request for Additional Information Set 3 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - E-mail
Project stage: RAI
PMNS20210548, Discussion of Dominion'S Response to Select Staff RAIs on North Anna Subsequent License Renewal Application2021-05-12012 May 2021
Discussion of Dominion'S Response to Select Staff RAIs on North Anna Subsequent License Renewal Application
Project stage: RAI
ML21132A2892021-05-13013 May 2021
SLRA RAI Response Public Meeting
Project stage: RAI
ML21145A2172021-05-13013 May 2021
Discussion on May 13, 2021 with Dominion on Select Staff RAIs on North Anna Subsequent License Renewal Application - Dominion Slides
Project stage: Other
PMNS20210666, Discussion of Dominion'S Response to Select Staff RAIs on North Anna Subsequent License Renewal Application2021-05-27027 May 2021
Discussion of Dominion'S Response to Select Staff RAIs on North Anna Subsequent License Renewal Application
Project stage: RAI
ML21221A1542021-05-27027 May 2021
Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - Dominion Slides
Project stage: Meeting
ML21221A1482021-05-27027 May 2021
Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - NRC Slides
Project stage: RAI
ML21147A2932021-05-27027 May 2021
(Naps), Units 1 and 2 Subsequent License Renewal Application (SLRA) Response to NRC Request for Additional Information Safety Review - Set 3 and Administrative Change to SLRA Table A4.0-1, Item 25
Project stage: Response to RAI
ML21221A1292021-05-27027 May 2021, 10 August 2021
05/27/2021 Meeting Summary: Discussion of Dominions Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application
Project stage: Request
ML21145A2132021-06-0909 June 2021
Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - Enclosure 1 - Summary
Project stage: RAI
ML21145A2152021-06-0909 June 2021
Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - Enclosure 2 - List of Attendees
Project stage: RAI
ML21145A2122021-06-0909 June 2021
Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - Memoranda
Project stage: RAI
PMNS20210777, Discussion of Dominion'S Response to Select Staff RAIs on North Anna Subsequent License Renewal Application - Topics to Be Determined2021-06-15015 June 2021
Discussion of Dominion'S Response to Select Staff RAIs on North Anna Subsequent License Renewal Application - Topics to Be Determined
Project stage: RAI
ML21166A3512021-06-15015 June 2021
Safety RAIs - Set 4 - Draft
Project stage: Draft RAI
ML21174A1952021-06-23023 June 2021
Safety RAIs - Set Y - Draft - Enclosure
Project stage: Draft RAI
PMNS20210778, Discussion of Dominion'S Response to Select Staff RAIs on North Anna Subsequent License Renewal Application - Topics to Be Determined2021-06-23023 June 2021
Discussion of Dominion'S Response to Select Staff RAIs on North Anna Subsequent License Renewal Application - Topics to Be Determined
Project stage: RAI
ML21174A3042021-06-23023 June 2021
SLRA RAI Response Public Meeting - 21-06-24
Project stage: RAI
ML21181A1272021-06-30030 June 2021
Issuance of Environmental Scoping Summary Report Associated with the NRC Staffs Review of the North Anna Power Station, Unit Nos. 1 and 2, Subsequent License Renewal Application
Project stage: Request
ML21188A1602021-07-0707 July 2021
Final Request for Additional Information Set 4 - North Anna SLRA Safety Review
Project stage: Request
ML21188A1632021-07-0707 July 2021
Final Request for Additional Information Set 4 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Email
Project stage: RAI
ML21188A1652021-07-0707 July 2021
Final Request for Additional Information Set 4 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure
Project stage: RAI
ML21210A3962021-07-29029 July 2021
(Naps), Units 1 and 2 - Subsequent License Renewal Application (SLRA) Response to NRC Request for Additional Information Safety Review - Set 4 and Supplement 3
Project stage: Supplement
ML21217A1872021-08-0505 August 2021
(Naps), Units 1 and 2 - Subsequent License Renewal Application First 10 CFR 54.21 (B) Annual Amendment
Project stage: Other
ML21221A1412021-08-10010 August 2021
Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - Attendees
Project stage: RAI
ML21221A1382021-08-10010 August 2021
Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application (EPID No. L-2020-SLR-0000) - Meeting Summary
Project stage: RAI
ML21221A1362021-08-10010 August 2021
Meeting Summary: Discussion of Dominion'S Response to Select Staff Requests for Additional Information on Subsequent License Renewal Application
Project stage: RAI
ML21225A5512021-08-13013 August 2021
Discussion Point for Public Meeting Regarding Fire Protection Piping Cyclic Loading - Transmittal E-mail
Project stage: Meeting
2021-04-29
[Table View] |
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Category:Request for Additional Information (RAI)
MONTHYEARML24087A0112024-03-23023 March 2024
NRR E-mail Capture - Draft RAIs for Reactor Coolant Pump (RCP) Relief Request (L-2024-LLR-0022)
ML23318A1172023-11-13013 November 2023
NRR E-mail Capture - Formal Issuance of RAIs for North Anna Technical Support Center (TSC) License Amendment Request (LAR) (L-2023-LLA-0006)
ML23257A2092023-09-14014 September 2023
NRR E-mail Capture - Formal Issuance of 2nd Round RAIs for Surry Units 1&2 and North Anna Units 1&2 Emergency Plans LAR
ML23243A9862023-08-31031 August 2023
NRR E-mail Capture - Draft RAIs for EP Staff Augmentation Times LAR (L-2022-LLA-0166)
ML23219A1602023-08-0707 August 2023
003 Radiation Safety Baseline Inspection Information Request
ML23171B0522023-06-20020 June 2023
NRR E-mail Capture - RAI for Review of Appendix F to DOM-NAF-2-P (Redacted)
ML23081A5282023-04-26026 April 2023
Request for Additional Information - North Anna Subsequent License Renewal Application Environmental Review
ML23075A0232023-03-15015 March 2023
NRR E-mail Capture - RAI - License Amend Req (LAR) to Revise Tech Spec (Ts) 3.6.8 Limiting Condition for Operation to Remove Refueling Water Chemical Addition Tank and Replace the Containment Sump Buffer North Anna, 1 and 2 (L-2022-LLA-0162
ML23060A0932023-03-0101 March 2023
NRR E-mail Capture - Formal Issuance of RAIs for Surry/North Anna Emergency Plans LAR
ML23059A2282023-02-28028 February 2023
NRR E-mail Capture - Draft RAIs for Containment Buffer Change to Natb (L-2022-LLA-0162)
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)
ML22083A2102022-03-24024 March 2022
NRR E-mail Capture - Draft RAI - Relief Request N2-14-LMT-003 Fourth Ten Year Inservice Inspection Interval
ML21327A3652021-11-23023 November 2021
NRR E-mail Capture - Draft RAI for TSTF-577 LAR
ML21322A0962021-11-18018 November 2021
Final Request for Additional Information Set 5 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Email
ML21322A0992021-11-18018 November 2021
Final Request for Additional Information Set 5 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure
ML21256A0672021-09-13013 September 2021
Final Request for Confirmation of Information Set 2 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Email
ML21256A0692021-09-13013 September 2021
Final Request for Confirmation of Information Set 2 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Request for Confirmation of Information
ML21238A0942021-08-25025 August 2021
Draft Request for Additional Information Set Z - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Email
ML21238A0982021-08-25025 August 2021
Draft Request for Additional Information Set Z - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure
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
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
ML21188A1632021-07-0707 July 2021
Final Request for Additional Information Set 4 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Email
ML21188A1652021-07-0707 July 2021
Final Request for Additional Information Set 4 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure
ML21174A1952021-06-23023 June 2021
Safety RAIs - Set Y - Draft - Enclosure
ML21166A3512021-06-15015 June 2021
Safety RAIs - Set 4 - Draft
ML21123A2972021-05-0303 May 2021
Final Request for Additional Information Set 3 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - E-mail
ML21123A2982021-05-0303 May 2021
Final Request for Additional Information Set 3 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure
ML21091A0032021-04-0101 April 2021
Final Request for Additional Information Set 2 - North Anna SLRA Safety Review (EPID No. L-2020-SLR-0000) - Enclosure 1 - RAIs
ML21091A0042021-04-0101 April 2021
SLRA Safety Review - Withdrawn Requests for Information (EPID No. L-2020-SLR-0000) - Enclosure 2
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)
ML21075A0032021-03-12012 March 2021
Emergency Preparedness Exercise Inspection Request for Information for - Brunswick, Catawba, North Anna, Oconee, Vogtle 1 & 2
ML21063A5602021-03-0404 March 2021
Final Request for Additional Information Set 1 - North Anna SLRA Safety Review (EPID L-2020-SLR-0000) - Enclosure
ML21049A0212021-02-17017 February 2021
Notification of an NRC Fire Protection Team Inspection (FPTI) (NRC Inspection Report 05000338/2021012 and 05000339/2021012) and Request for Information (RFI)
ML21028A3902021-01-29029 January 2021
Request for Additional Information - North Anna Subsequent License Renewal Application Environmental Review (EPID Number: L-2020-SLE-0000) (Docket: 50-338 and 50-339)
ML21028A4352021-01-28028 January 2021
Notification of Target Set Inspection and Request for Information (NRC Inspection Report No. 05000338/2021404 and 05000339/2021404)
ML21012A3412021-01-22022 January 2021
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ML20316A0422020-11-10010 November 2020
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ML20223A3412020-08-10010 August 2020
003 Radiation Safety Baseline Inspection Information Request
ML20218A4282020-08-0505 August 2020
Notification of Inspection and Request for Information
ML20125A0762020-05-0101 May 2020
NRR E-mail Capture - Draft RAI Related to Revised Reactor Vessel Material Surveillance Capsule Withdrawal Schedule Dominion Energy Virginia North Anna Power Station Units 1 and 2 (L-2020-LLL-0038)
ML20113A5792020-04-21021 April 2020
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ML19354B6142019-12-20020 December 2019
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ML19317F1042019-11-0707 November 2019
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ML19191A2512019-07-10010 July 2019
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ML19169A0962019-06-17017 June 2019
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ML19162A0052019-06-10010 June 2019
NRR E-mail Capture - Draft RAIs for Dominion EAL Scheme Change
ML19108A1902019-04-18018 April 2019
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ML19060A2432019-03-0101 March 2019
Related to License Amendment Request to Address Open Phase Conditions
2024-03-23
[Table view] |
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NORTH ANNA POWER STATION, UNITS 1 AND 2 (NAPS)
SUBSEQUENT LICENSE RENEWAL APPLICATION (SLRA)
REQUESTS FOR ADDITIONAL INFORMATION (RAIS)
SAFETY - SET 5
- 1. Buried and Underground Piping and Tanks, AMP XI.M41
Regulatory Basis: Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(3) requires an applicant to demonstrate that, for components withi n the scope of license renewal, the effects of aging will be adequately managed to maintain the components intended function(s) consistent with the current licensing basis for the period of extended operation. One of the findings that the Nuclear Regulatory Commission (NRC) st aff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been ide ntified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of components that have been identified to re quire review under 10 CFR 54.21, such that there is reasonable assurance that the activities aut horized by the renewed license will continue to be conducted in accordance with the current li censing basis. To complete its review and enable formulation of a finding under 10 CFR 54.29(a ), the staff is requesting additional information regarding the matters described below.
Background:
As required by 10 CFR 54.21(d), each [subsequent] license renewal application (SLRA) must include a final safety analysis report (FSAR) suppl ement containing a summary description of the programs and activities determined by 10 CFR 54.21(a) for managing the effects of aging. In its discussions about FSAR supplements, N RC Standard Review Plan for Subsequent License Renewal (SRP-SLR), Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, (NUREG-2192, Revision 0, July 2017)
(ADAMS Accession No. ML17187A204) Section 3.3.2.5 notes that t he FSAR supplement description should be sufficiently comprehensive such that late r changes to the program can be controlled by 10 CFR 50.59 Changes, Tests, and Experiments. The SRP-SLR also notes that the program description should include any future aging managem ent activities including enhancements and commitments and contain the bases for determin ing that aging effects will be managed. The SRP-SLR further notes that the type of informa tion to be included is provided in NUREG-2191, Revision 0, Generic Aging Lessons Learned for S ubsequent License Renewal (GALL-SLR) Report, dated July 2017 (ADAMS Accession No. ML17187A031),
Table XI-01, FSAR Supplement Summaries for GALL-SLR Report Cha pter XI Aging Management Programs [AMP].
As amended by Supplement 4 to the SLRA (letter dated August 26, 2021, ADAMS Accession No. ML21238A297), Dominion Energy included extensive changes to the program description in SLRA Section B2.1.27, Buried and Underground Piping and Tanks. Supplement 4 adds a new Enhancement (No. 6) to reflect the deletion of jockey pump moni toring as the basis for not performing excavated direct visual inspection of the buried gra y cast iron fire main piping. The new enhancement describes the performance of nondestructive exa minations (i.e., magnetic particle and radiographic testing) of the excavated piping, and destructive examinations of any identified bounding cracks, with engineering evaluations of cra ck growth, and flaw stability to address cracking due to cyclic loading. Supplement 4 also modi fies Enhancement No. 5 to the Buried and Underground Piping and Tanks program to provide for destructive examinations of the excavated gray cast iron pipe as given in GALL-SLR AMP XI.M 33, Selective Leaching.
Supplement 4 to the application also modified SLRA Section A1, Summary Description of Aging Management Programs, and SLRA Section A1.27, Buried an d Underground Piping and Tanks, by adding the sentence: The program will also manage cracking due to cyclic loading in buried gray cast iron fire protection piping that is lined w ith a cementitious coating. A previous supplement had deleted the discussion about monitoring jockey pump activity in lieu of performing visual inspections of buried fire protection system components. The staff notes that Supplement 4 also modified SLRA Table A4.0-1, Subsequent Licen se Renewal Commitments, Item 27 to describe the commitments to revise procedures for En hancements No. 5 and No.6.
As documented in the NRCs Determination of Acceptability and S ufficiency for Docketing associated with the SLRA (letter dated October 13, 2020, ADAMS Accession No. ML20258A284), the GALL-SLR Report does not address cracking due to cyclic loading for buried gray cast iron piping. Dominion recognized this aspect when it eventually cited an aging management review item with generic note H (indicating the agin g affect was not in the GALL-SLR Report) for cracking due to cyclic loading that will b e managed by the Buried and Underground Piping and Tanks program.
Because the aging effect for the given material and environment combination is not addressed in the GALL-SLR Report, the FSAR program description in GALL-SL R Table XI-01 for the Buried and Underground Piping and Tanks AMP would not be suffic ient. The staff notes that the SLRA did not initially address cracking due to cyclic loadi ng and after substantially enhancing the Buried and Underground Piping and Tank program on ly a single sentence (noted above) was added to the FSAR program description. The staff al so notes that although the table with subsequent license renewal commitments includes a de scription of the programs enhancements, once commitments (e.g., to revise procedures) hav e been completed, they can, and have been deleted from the commitment table.
RAI 4.7.6-1
Issue: In order to ensure that changes to the program, which c ould decrease the overall effectiveness of the program to manage the effects of aging, wi ll receive appropriate review by a licensee, the FSAR supplement s hould be sufficiently comprehens ive. The FSAR supplement in SLRA Section A1.27, Buried and Underground Piping and Tanks, appears to lack a sufficient description of the activities for managing cracking due to cyclic loading to provide appropriate administrative and regulatory controls for the prog ram. The current program includes specific nondestructive and destructive inspections of excavated gray cast iron piping and relatively unique engineering evaluations of crack growth a nd flaw stability in a brittle material that are not described in the current FSAR supplement. In addition, specific activities for managing the loss of material due to selective leaching are being performed as part of the Buried and Underground Piping and Tanks program; however, these activities are not referenced or otherwise noted in SLRA Section A1.21, Selective Leaching. The staff cannot complete its review of the above FSAR supplements without addit ional information.
Request: Provide additional information that either: (a) expl ains how the current FSAR supplement descriptions in SLRA Section A1.27 for of the Buried and Underground Piping and Tanks program and SLRA Section A1.21 for the Selective Leaching program will provide appropriate administrative and regulatory controls to ensure th at any future changes to the programs will not decrease their overall effectiveness to manag e the effects of aging, or (b) modifies the associated FSAR supplements to include a more detailed description of the programs and aging management activities.
