ML19198A059

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Subsequent License Renewal Application - Response to NRC Requests for Confirmation of Information
ML19198A059
Person / Time
Site: Surry  Dominion icon.png
Issue date: 07/11/2019
From: Gerald Bichof
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
19-258
Download: ML19198A059 (17)
v • d • e


Text

,... \.Jlo VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 11, 2019 United States Nuclear Regulatory Gommission Attention:

Document Control Desk Washington, D.C. 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION 10 CFR 50 10 CFR 51 10 CFR 54 Serial No.: 19-258 NRA/GDM: R1 Docket Nos.: 50-280 50-281 License Nos.: ,DPR-32 DPR-37 RESPONSE TO NRC REQUESTS FOR CONFIRMATION OF INFORMATION

References:

1. Letter from Virginia Electric and Power Company to the US Nuclear Regulatory Commission dated October 15, 2018 (Serial No.18-340), "Virginia Electric and Power Company, Surry Power Station Units 1 and 2, Application for Subsequent Renewed Operating Licenses," [Agencywide Documents Access and Management System (ADAMS) Accession No. ML18291A842]
2. Email from Emmanuel Sayoc of the US Nuclear Regulatory Commission to Daniel G. Stoddard of Virginia Electric and Power Company dated June 12, 2019, "Requests for Confirmation of Information for the Safety Review of the Surry Power Station, . Units 1 and 2 Subsequent License Renewal Application (L-2018-RNW-0023/000951)

-(Attachment 4D)" In Reference 1, Virginia Electric and Power Company (Dominion Energy Virginia) submitted the Subsequent License Renewal Application (SLRA) for Surry Power Station (SPS) Units 1 and 2. In Reference 2, the NRC provided requests for confirmation of information (RCls) the staff will likely use in the conclusions documented in their Safety . Evaluation Report {SER) for the SLRA, but which has not been previously docketed.

The NRC RCls and Dominion Energy Virginia's confirmation of each RCI are provided in the enclosure.

.. Serial No.19-258 Docket Nos. 50-280/281 SLRA -Response to NRC RCls Page 2 of 6 If you have any questions or require additional information, please contact Mr. Paul Aitken at (804) 273-2818.

Sincerely, !::!::ff-D Senior Vice President

-Nuclear Operations and Fleet Performance Commitments made in this letter: None

Enclosure:

Response to NRC Requests for Confirmation of Information COMMONWEAL TH OF VIRGINIA ) ) COUNTY OF HENRICO ) The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Senior Vice President

-Nuclear Operations and Fleet Performance of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief. Acknowledged before me this l \--\:!, day of , 2019. My Commission Expires: ~OA.t.h 31, 20Z2. Notary Public DIANE E. AITKEN NOTARY PUBLIC REG. #7763114 COMMONWEAL TH OF VIRGINIA MY COMMISSION EXPIRES MARCH 31. 2022 cc: (w/o Enclosures except *) U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station Mr. Emmanuel Sayoc

& Consumer Services 102 Governor Street Richmond, Virginia 23219 Mr. Jason Bulluck, Director Virginia Department of Conservation

& Recreation Virginia Natural Heritage Program 600 East Main Street, 24th Floor Richmond, VA 23219 Mr. Robert W. Duncan, Director Virginia Department of Game and Inland Fisheries P.O. Box 90778 Henrico, VA 23228 Mr. Allen Knapp, Director Virginia Department of Health Office of Environmental Health Services 1 09 Governor St, 5th Floor Richmond, VA 23129 Ms. Julie Lagan, Director Virginia Department of Historic Resources State Historic Preservation Office 2801 Kensington Ave Richmond, VA 23221 Mr. Steven G. Bowman, Commissioner Virginia Marine Resources Commission 2600 Washington Ave Newport News, VA 23607 Dr. Mary Fabrizio, Professor Virginia Institute of Marine Science School of Marine Science 7509 Roper Rd, Nunnally Hall 135 Gloucester Point, VA 23062 Ms. Angel Deem, Director Virginia Department of Transportation Environmental Division 1401 East Broad St Richmond, VA 23219 Mr. Stephen Moret, President Virginia Economic Development Partnership 901 East Byrd St Richmond, VA 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Public Utility Regulation 1300 East Main St, 4th Fl, Tyler Bldg Richmond, VA 23219 Mr. Jeff Caldwell, Director Virginia Department of Emergency Management 10501 Trade Rd Richmond, VA 23236 Mr. Bruce Sterling, Chief Regional Coordinator Virginia Department of Emergency Management 7511 Burbage Drive Suffolk, VA 23435 Mr. Jonathan Lynn, Administrator Surry County 45 School Street Surry, VA 23883 Serial No.19-258 Docket Nos. 50-280/281 SLRA -Response to NRG RCls Page 6 of 6 Enclosure Serial No.: 19-258 Pocket Nos.: 50-280/281 RESPONSE TO NRC REQUESTS FOR CONFIRMATION OF INFORMATION

\ Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2 Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure Response to NRC Requests for Confirmation of Information Subsequent License Renewal Application Surry Power Station Units 1 and 2 By letter dated October 15, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18291A842), as supplemented by letters dated January 29, 2019 (ADAMS Accession No. ML19042A137), and April 2, 2019 (ADAMS Accession No. ML19095A666), Virginia Electric and Power Company (Dominion Energy Virginia or Dominion) submitted an application for the subsequent license renewal of Renewed Facility Operating License Nos. DPR-32 and DPR-37 for Surry Power Station (SPS) Units 1 and 2, respectively.

Between February 4 and April 25, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff conducted audits of Dominion records to confirm information submitted in the SPS Subsequent License Renewal Application (SLRA). During the audits, the staff reviewed several documents that contain information that will likely be used in conclusions documented in the Safety Evaluation Report (SER), but which has not been previously submitted to the NRC on the docket. Any information used to reach a conclusion in the SER must be included on the docket by the applicant.

Therefore, in an email dated June 12, 2019, the NRC staff transmitted fifteen requests for confirmation of information (RCls) gathered during the audits noted above. The NRC RCls and Dominion Energy Virginia's confirmation of each RCI are provided below. REQUESTS FOR CONFIRMATION OF INFORMATION (RCls) RCI No.1: The staff reviewed Table 6.1-1, Augmented Inspections," Item 2.2.1, "Containment and Recirculation Spray Piping," from the Technical Requirements Manual and noted that: (a) six nine-inch square patches will be examined by visual (VT-1) and surface examination; and (b) at least 25 percent of the inspection locations are inspected in each one-third portion of each inservice inspection 10-year interval.

This input will be used in SER Section 3.2.2.2.4.

Dominion Response:

This information has been confirmed to be correct as stated. Page 1 of 10 RCI No. 2: Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure Based on the review of calculation 11448-EA-62, Addendum DOC, "Reactor Containment Liner Fatigue Evaluation for 80-Year Plant Life, Surry Unit 1 and Unit 2," Revision 0, the staff noted that for satisfying Condition 2 -Normal Operation Pressure Fluctuation, of the ASME Code Section Ill (1968), Subsection N-415.1, the calculation conservatively evaluated the cumulative damage effect, due to 100 cycles of the Type A test pressure fluctuation of 50. 18 psi in addition to the 2000 cycles of normal operating pressure fluctuation of 5.2 psi, to be 0.052 which is Jess than the cumulative fatigue damage acceptance criteria of 1.0. Dominion Response:

This information has been confirmed to be correct as stated. RCI No. 3: Based on the review of calculation CE-1272, Addendum OOB, "Fuel Pool Liner Fatigue Evaluation for 80 Years Plant Life, Surry Unit 1 and Unit 2," Revision 0, the staff noted that the cumulative damage due to fatigue effects (thermal cyclic loadings) for the controlling component (i.e., plate-stiffener weld) from the three design conditions described in SLRA Section 4. 7.4 was calculated to be 0. 75, which is Jess than the cumulative fatigue damage acceptance criteria of 1.0. Dominion Response:

This information has been confirmed to be correct as stated. RCI No. 4: Based on the review of procedures ER-AA-FAC-10, "Flow-Accelerated Corrosion Program," Revision 7, and ER-AA-FAC-102, "Flow-Accelerated Corrosion (FAG) Inspection and Evaluation Activities," Revision 0, the staff noted that these procedures contain aspects of the applicant's Erosion program. The requirements in these procedures also apply to the site Erosion program. Dominion Response:

This information has been confirmed to be correct as stated. Page 2 of 10 RCI No. 5: Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure SLRA Table 2.3.1-1-Reactor Vessel: The intended function for the Seal Table in Reactor Vessel (SLRA Table 2.3.1-1, page 2-57) is for "Structural Support." This is due to the seal table being welded to the thimble tube conduits, which is not wetted, and does not perform a pressure boundary function, but does provide support to the thimble tube conduits.

Dominion Response:

This information has been confirmed to be correct as stated. RCI No. 6: SLRA Table 2.3.1-2-Reactor Vessel Internals:

The following components:

diffuser plate, head and vessel alignment pins, head cooling spray nozzles, and upper instrumentation conduit and support (tubes, conduits, flange base, locking caps and support tubes) are now categorized as "no additional measures" components and require "no additional measures" for aging management.

Dominion Response:

This information has been confirmed to be correct as stated. RCI No. 7: SLRA Table 2.3.1-3-Reactor Coolant-Heat Exchanger (Tube): The intended function for Heat exchanger (reactor coolant pump motor upper bearing oil cooler -tubes and tube sheet) is only specified as "Pressure Boundary" but not added with "Heat Transfer." This is due to the reactor coolant pump lubricating oil heat exchangers not being required to remove heat, but to perform the pressure boundary function for the license renewal. Dominion Response:

This information has been confirmed to be correct as stated with respect to the component cooling water system pressure boundary function.

RCI No. 8: SLRA Table 2.3.1-3-Reactor Coolant-Pressurizer (Thermal Sleeve): The intended function for both Pressurizer (spray nozzle thermal sleeve) and Pressurizer (surge nozzle thermal sleeve) is to "Limit Thermal Cycling" and not "Pressure Boundary." Page 3 of 10 Dominion Response:

This information has been confirmed to be correct as stated. RCI No. 9: Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure SLRA Table 2.3.2-1-Containment Spray -Flow Element: The intended function for containment spray flow element is "Structural Integrity".

This is due to these flow elements and the associated piping being outdoors and functioning to provide structural support to the attached safety-related piping that connects to the refueling water storage tanks. Dominion Response:

This information has been confirmed to be correct as stated. RCI No. 10: It is NRG staff's understanding that Dominion Energy inadvertently left out of SPS SLR ER RAJ VAR-1 (i) response, pages 2-6 of Attachment B of the VPDES Fact Sheet. Dominion Response:

This information has been confirmed to be correct as stated. NRC subsequently determined that pages 2-6 of Attachment B of the VPDES Fact Sheet were not necessary for completion of the environmental review. RCI No. 11: The staff reviewed the In-Service Internal Tank Inspection Reports for the FWSTs, 01-FP-TK-1 A and 01-FP-TK-1 B, and noted that: (a) the 2019 inspections consisted of taking tank bottom UT thickness measurements in approximately 87,000 locations for 01-FP-TK-1A and 84,000 locations for 01-FP-TK-1 B; (b) the scanned area included the tank bottom and bottom course of the tank shell; (c) the nominal thickness for the bottom plates is 0.3125 inches; (d) the lowest observed thickness reading of the tank bottom plates for 01-FP-TK-1A was 0.2120 inches and 0.2388 inches for01-FP-TK-1B; (e) an extreme value analysis was conducted, which resulted in predicted minimum thickness of 0.2111 inches for 01-FP-TK-1A and 0.2203 inches for 01-FP-TK-18.

Page 4 of 10 Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure The reports also stated that it detected laminations in the tank bottom plates but not in the bottom course of the tank shell. The report concluded that the previous tank measurements did not account for the fact that there were laminations and recorded the thickness of the top lamination layer and not the entire thickness of the tank bottom plates. The 2019 inspection was able to replicate the lamination data in at least one location for 01-FP-TK-1 A based on a review of the thickness results from the 2008 and 2014 inspections as compared to the measured thickness of the lamination in 2019. The minimum wall thickness measurement for the bottom course of the tank shell was 0.2550 inches for 01-FP-TK-1A and 0.3650 inches for 01-FP-TK-18.

The minimum wall thickness required is 0.115 inches. Using the predicted minimum thickness value, the tanks have a projected useful remaining life of 55 years for 01-Fj='-TK-1 A and 66 years for 01-FP-TK-1 B. Dominion Response:

This information has been confirmed to be correct as stated. RCI No. 12: The staff reviewed the below work orders (WO) and noted the following regarding testing of the fire pumps [gallons per minute (gpm), total dynamic head (TOH), pounds per square inch differential (psid)J: Year 2500 gpm TOH, psid 3050 gpm TOH, psid WO Diesel Driven Pump 2019 113 106 38103851700 2018 115 107 38103756472 2016 113.5 107.5 38103679516 2015 113.5 106 381035707 43 2014 114 108 38103457968 Motor Driven Pump 2019 117 98 38103851700 2018 116 116 38103758472 2016 112.8 91.6 38103679516 2015 116.4 117 381035707 43 2014 116 91 38103457968 For the diesel driven pump tests the variability of the TOH results at both the 2500 and 3050 gallons per minute test runs were not indicative of an increase in flow blockage in the fire main piping. For the motor driven pump tests there were two anomalous results, Page 5 of 10 Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure which were preceded and followed by lower system pressure and therefore not indicative of an increase in flow blockage in the fire main piping. Dominion Response:

This information has been confirmed to be correct as stated, with the exception of the 2018 Motor Driven Pump work order reference.

The work order number should be the same as the work order number listed for the 2018 Diesel Driven Pump, i.e., work order number 3810375§472 should be 3810375§472.

RCI No. 13: During the three phases of the audit, the staff identified multiple conditions reports associated with potential buried fire water system leakage. Condition Year Brief Description Report Number 1 105806 2008 Surface water was detected near a fire hydrant adjacent to the training center parking lot. The follow-on actions noted that a tee was leaking. The tee is not in-scope.

The staff reviewed WO 38102396326, associated with Condition Report (CR) 105806 and noted that the repair consisted of replacing a gasket and tightening bolting. 2 474655 2012 Surface water was detected in the vicinity of post indicating valve 1-FP-1024.

The piping is not in-scope.

The staff reviewed WO 038103256391 associated with CR 47 4655 and noted that the repair consisted of replacing gaskets, a-rings, and fasteners.

3 504380 2013 Surface water was detected in the vicinity of 1-FP-1027.

A hydrant and gate valve were replaced.

Neither is in-scope. The staff reviewed WO 38103115596 associated with CR 504380 and noted that the repair consisted of replacing a hydrant and two isolation valves. The hydrant and valve degradation were not associated with the pressure boundary (e.g., stem damage). 4 556008 2014 Surface water was detected in the vicinity of 1-FP-535.

Closed to a work order in planning.

The work order was subsequently closed because a walkdown revealed that there were no indications of leakaqe. 5 580443 2015 Surface water was detected in the vicinity of 1-FP-542.

Closed to a work order in planning.

There is no in-scope piping in the vicinity.

WO 38103627995 closed based on followup inspection that did not reveal anv leakaqe. Page 6 of 10 Condition Year Report Number 6 1086752 2017 7 1019199 2015 8 329250 2009 9 345000 2009 10 477285 2012 11 553533 2014 ' 12 1079710 2017 13 330747 2009 14 456235 2011 15 470098 2012 16 497754 2012 17 498946 2012 18 510828 2013 Brief Description Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure Surface water was detected in the vicinity of 1-FP-379; by the training center. Closed to a work order in planning.

The valve is not in-scope.

WO 102939749 closed based on followup inspection that did not reveal any leakaqe. Surface water was detected in the vicinity of 1-FP-321.

Work order in planning.

The cause of the surface water indications was a failure of the upper valve plate (on 1-FP-326) to isolate the drain ring. The valve is not in-scope. Surface water was detected at the north east corner of a construction site laydown area within 100 feet of 1-FP-1046. The work order was closed because follow-on inspections did not detect a leak. Surface water was detected in the vicinity of post indicating valve 01-FP-86.

The work order was closed because follow-on inspections did not detect a leak. Surface water was detected in the vicinity of hose house 29. A follow-on inspection could not recreate the conditions.

Surface water was detected in the vicinity of hose house 13. The work order was closed because follow-on inspections did not detect a leak. Surface water was detected in and around fire hose house 31; less than one gallon per hour. The work order was closed because follow-on inspections did not detect a leak. Surface water was detected in the vicinity of the station training center. A concrete kicker moved, allowing the pipe to slide out of the tee. Surface water was detected in the vicinity of fire hydrant 1-FP-708.

The hydrant flange joint was leaking, not the pressure boundary.

Retightened fittings and conducted a 6-hour leak check. Surface water was detected in the vicinity of 1-FP-100.

Closed to work order to repair a packing leak. Surface water was detected in the vicinity of curb box valve 1-FP-1010.

The cause was an out of position valve. Surface water was detected in the vicinity of post indicating valve 1-FP-49. The leak was caused by a packing leak. Surface water was detected in the vicinity of post indicating valve 1-FP-35. The stuffing flange was broken causinq a packing leak. Page 7 of 10 Condition Report Number 19 538837 20 1087963 Year 2014 2018 Brief Description Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure Surface water was detected in the vicinity of the curb box near 1-FP-70. The leak was caused bv a packina leak. Surface water was detected between 1-FP-124 and 1-FP-519. Leak was actually in the domestic water system, not fire water system. This portion of the domestic water svstem is not in-scope.

Dominion Response:

This information has been confirmed to be correct as stated. RCI No. 14: The staff reviewed the Sprinkler Operating Experience Summary and noted the following:

Condition Year Brief Description Summary of Conditions Report Number 002099 2006 A sprinkler head at the west Sprinkler was replaced with end of the unit 2 condenser the minor maintenance was found to be leaking at 40 process and no work order drops per minute (dpm). The generated.

work order was cancelled.

007510 2007 A sprinkler head in the laundry Heating unit in the building building was found to be failed, which allowed ice to spraying a fine mist. Closed to build up on the sprinkler a work order. head. This is event driven, not aqina. 485731 2012 Corrosion was detected on a A walkdown was conducted sprinkler in the chemistry and the sprinkler head was primary hot lab. No follow-on determined to be functional.

information was provided.

496505 2012 A sprinkler head in the turbine CRs documented the same building was found to be condition adverse to leaking at 10 dpm. A quality. Leakage occurred subsequent condition report, due to a broken fuse, not 497330, stated that the leak an aging effect. Significant had increased to 2 dps. A outage work was being follow-on inspection noted that conducted in the vicinity the fuse was missinq. when the damaqe Page 8 of 10 497330 2012 497373 2012 503979 2013 1080715 2017 [1080728 was a possible typo in the Operating Experience Audit Reportl Dominion Response:

A sprinkler head was found to be leaking in the unit 2 turbine building at 2 dps. A follow-on inspection noted that the fuse was missing. Sprinkler head failed, previously leaking at 10 dpm. A unit 2 turbine building / sprinkler head was found to be spraying water. A follow-on inspection noted that the fuse was missing. A sprinkler head above the unit 2 air ejector failed. No follow-on information was provided.

Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure occurred.

Sprinkler head fuse assembly was missing. Not an aging issue. WO documented that sprinkler head internals were missing. Not an aging effect. This information has been confirmed to be correct as stated. RCI No.15: The staff reviewed the Main Drain Operating Experience Summary and noted the following:

Condition Year Brief Description Summary of Condition Report Number 380377 2010 The sensing line upstream of a The plugged line was a main drain gauge isolation valve is 3/8-inch test connection at the clogged as evidenced by the static end of the header resulting in a and dynamic pressure reading collection point for rust. The being the same. function of the downstream sprinklers was never affected.

Page 9 of 10 Condition Year Brief Description Report Number 393845 2010 A drain on unit 1 south side turbine building is clogged. A subsequent condition report, 398027 (10/06/2010), confirmed that blockage was not downstream of the drain valve. 398027 2010 Approximately one inch of rusty debris blocked line I 463714 2012 Approximately one inch of rusty debris blocked line 496837 2012 The strainer downstream of an inspector test valve is clogged with debris and damaged beyond repair. 1044047 2016 Clogged fire water line. Dominion Response:

Serial No.: 19-258 Docket Nos.: 50-280/281 Enclosure Summary of Condition The test connection is a tee off of the main header and based on configuration it is a low point where rust debris could accumulate.

The test line was not functional until the line was cleared; however, the function of the downstream sprinklers was never affected.

The test connection is a tee off of the main header and based on configuration it is a low point where rust debris could accumulate.

The test line was not functional until the line was cleared; however, the function of the downstream sprinklers was never affected.

The test connection is a tee off of the main header and based on configuration it is a low point where rust debris could accumulate.

The test line was not functional until the line was cleared; however, the function of the downstream sprinklers was never affected.

The strainers were replaced because they were constructed of too fine of a mesh for use with well water applications.

The blockage occurred because the vent line we/do/et was not installed correctly and the corrective action was to drill through the piping/we/do/et to allow flow when required.

This information has been confirmed to be correct as stated. Page 10 of 10

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