ML25079A198

License Amendment Request - Proposed Revision to Administrative Control Technical Specification for Containment Leakage Rate Testing Program

ML25079A198
Person / Time
Site:	Summer
Issue date:	03/20/2025
From:	James Holloway Dominion Energy South Carolina
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
25-045
Download: ML25079A198 (1)

Text

Dominion Energy South Carolina, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 DominionEnergy.com March 20, 2025 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 DOMINION ENERGY SOUTH CAROLINA, INC.

VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 Serial No.

NRA/AF:

Docket No.

License No.

Dominion Energy'25-045 R1 50-395 NPF-12 LICENSE AMENDMENT REQUEST - PROPOSED REVISION TO ADMINISTRATIVE CONTROL TECHNICAL SPECIFICATION FOR CONTAINMENT LEAKAGE RATE TESTING PROGRAM Pursuant to 10 CFR 50.90, Dominion Energy South Carolina, Inc. (DESC) is hereby submitting a License Amendment Request (LAR) for Virgil C. Summer Nuclear Station (VCSNS) Unit 1.

The proposed amendment would revise the Technical Specifications (TS) for VCSNS Administrative Controls 6.8.4.g concerning the Containment Leakage Rate Testing Program. The proposed change will replace the reference to Nuclear Energy Institute (NEI) Technical Report 94-01, Revision 2-A "Industry Guideline for Implementing Performance-Based Option 10CFR50, Appendix J," October 2008 with NEI Technical Report 94-01, Revision 3-A, July 2012, and conditions and limitations specified in NEI 94-01, Revision 2-A. provides DESC's description and assessment of the proposed change. contains the Local Leak Rate Test Data Trend Summary and Program Implementation Review used to establish the justification for the request. Attachment 3 provides the marked-up VCSNS TS page to reflect the proposed amendment. provides the revised (clean) VCSNS TS page. There are no associated TS Bases changes.

The proposed amendment does not involve a Significant Hazards Consideration under the standards set forth in 10 CFR 50.92. The basis for this determination is included in. DESC has also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite, or any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

The proposed amendment has been reviewed and approved by the station's Facility Safety Review Committee.

Serial No.25-045 Docket No. 50-395 Page 2 of 3 DESC requests approval of this license amendment request by January 23, 2026, with a 30-day implementation period.

In accordance with 10 CFR 50.91 (b), a copy of this license amendment request is being provided to the State of South Carolina.

If you have any questions or require additional information, please contact Mr. Allen Fulmer at (804) 273-2268.

Respectfully, Y~-~1 James E. Holloway Vice President - Nuclear Engineering and Fleet Support COMMONWEAL TH OF VIRGINIA

)

COUNTY OF HENRICO

)

)

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by James E. Holloway, who is Vice President - Nuclear Engineering and Fleet Support of Dominion Energy South Carolina, Inc.

He has affirmed before me that he is duly authorized to execute and file the foregoing document on 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.2 Oday of ~

r e.A.

, 2025.

My Commission Expires:

-:Jun e

3 o,.2. o:i fs Attachments:

ALLEN FULMER NOTARY PUBLIC REG. #00286846 COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES JUNE 30, 2028 ~~-

Notary Public

1. Description and Assessment of Proposed Change

2. Local Leak Rate Test Data Trend Summary and Program Implementation Review

3. Marked-up Technical Specification Pages

4. Revised (Clean) VCSNS TS Page Commitments made in this letter: None

Serial No.25-045 Docket No. 50-395 Page 3 of 3 cc:

U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 Mr. G. Edward Miller NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 09 E-3 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector V. C. Summer Nuclear Station Director, Radiation Protection Program Bureau of Land and Waste Management 2600 Bull Street Columbia, SC 29201 Mr. G. J. Lindamood Santee Cooper - Nuclear Coordinator 1 Riverwood Drive Moncks Corner, SC 29461

Serial No.25-045 Docket No. 50-395 DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGE Dominion Energy South Carolina, Inc.

Virgil C. Summer Nuclear Station Unit 1

Serial No.25-045 Docket No. 50-395 TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION.................................................................................. 1 2.0 DETAILED DESCRIPTION.................................................................................. 1 2.1 CURRENT TECHNICAL SPECIFICATION REQUIREMENT............................................. 1

2.2 DESCRIPTION

OF PROPOSED CHANGES................................................................. 2 2.3 REASON FOR THE PROPOSED CHANGE................................................................. 2

3.0 TECHNICAL EVALUATION

................................................................................. 2

3.1 BACKGROUND

..................................................................................................... 2 3.2 SYSTEM DESIGN AND OPERATION......................................................................... 7

3.3 TECHNICAL ANALYSIS

.......................................................................................... 8 3.4 NRC SAFETY EVALUATION LIMITATIONS AND CONDITIONS.................................... 10

3.5 CONCLUSION

.................................................................................................... 14

4.0 REGULATORY EVALUATION

.......................................................................... 15 4.1 APPLICABLE REGULATORY REQUIREMENTS AND CRITERIA.................................... 15 4.2 PRECEDENTS.................................................................................................... 16 4.3 NO SIGNIFICANT HAZARDS CONSIDERATION........................................................ 16

4.4 CONCLUSION

.................................................................................................... 19

5.0 ENVIRONMENTAL CONSIDERATION

............................................................. 19

6.0 REFERENCES

................................................................................................... 20

Serial No.25-045 Docket No. 50-395, Page 1 of 22 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Dominion Energy South Carolina (DESC) requests an amendment to Renewed Facility Operating License NPF-12 for Virgil C. Summer Nuclear Station (VCSNS), Unit 1 to allow for permanent extension of the Type C Leakage Rate Testing frequencies.

The proposed change revises VCSNS Technical Speci"cation (TS) 6.8.4.g, "Containment Leakage Rate Testing Program" to re"ect the following:

Adopts an extension of the containment isolation valve (CIV) leakage rate testing (Type C) frequency from the 60 months currently permitted by 10 CFR 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, Option B, to a 75-month frequency for Type C leakage rate testing of selected components, in accordance with NEI 94-01, Revision 3-A.

Adopts a more conservative allowable test interval extension of nine months, for Type A, Type B, and Type C leakage rate tests in accordance with NEI 94-01, Revision 3-A.

Speci"cally, the proposed change contained herein revises VCSNS TS 6.8.4.g, by replacing the reference to NEI 94-01, Revision 2-A, with a reference to NEI 94-01, Revision 3-A, and the conditions and limitations speci"ed in NEI 94-01, Revision 2-A, as the documents used by DESC to implement the performance-based leakage testing program in accordance with Option B of 10 CFR 50, Appendix J.

This LAR does not impact the Type A integrated leakage rate test (ILRT) program test interval, which was previously extended to a permanent 15-year interval under Amendment No. 194, and maintains the conditions and limitations specified in NEI 94-01, Revision 2-A, required by that amendment.

2.0 DETAILED DESCRIPTION 2.1 Current Technical Specification Requirement VCSNS Unit 1 TS 6.8.4.g, Containment Leakage Rate Testing Program, currently states, in part:

A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modi"ed by approved exemptions. This program shall be in accordance with NEI 94-01, Revision 2-A, Industry Guidelines for

Serial No.25-045 Docket No. 50-395, Page 2 of 22 Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, October 2008.

2.2 Description of Proposed Changes The proposed changes to VCSNS Unit 1 TS 6.8.4.g will replace the reference to NEI 94-01 Revision 2-A with reference to NEI 94-01 Revision 3-A, and the conditions and limitations speci"ed in NEI 94-01, Revision 2-A.

The proposed change revises the VCSNS Unit 1 TS 6.8.4.g to read as follows:

A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modi"ed by approved exemptions. This program shall be in accordance with the guidelines contained in NEI 94-01 "Industry Guideline for Implementing Performance-Based Option of 10CFR50, Appendix J,"

Revision 3-A, dated July 2012, and the conditions and limitations speci"ed in NEI 94-01, Revision 2-A, dated October 2008.

Markups of the proposed TS changes are provided in Attachment 3 and a revised version of the TS is provided in Attachment 4.

2.3 Reason for the Proposed Change The revision of VCSNS Unit 1 TS 6.8.4.g to adopt NEI 94-01 Revision 3-A would allow for the Type C Local Leak Rate Test (LLRT) intervals to be extended to a maximum of 75 months. This extension would reduce the number of LLRTs that would be required each outage and would also assist with the implementation of the VCSNS plan for train-specific outages. DESC has evaluated the performance of the applicable components, and will implement the conditions and limitations of NEI 94-01, Revision 3-A, in support of this change.

3.0 TECHNICAL EVALUATION

3.1 Background

Chronology of Testing Requirements of 10 CFR 50, Appendix J The testing requirements of 10 CFR 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, provide assurance that leakage from the containment, including systems and components that penetrate the containment, does not exceed the allowable leakage values speci"ed in the TS. 10 CFR 50, Appendix J also ensures that periodic surveillance

Serial No.25-045 Docket No. 50-395, Page 3 of 22 of reactor containment penetrations and isolation valves are performed so that proper maintenance and repairs are made during the service life of the containment and those systems and components penetrating primary containment. The limitation on containment leakage provides assurance that the containment would perform its design function following an accident up to and including the plant design basis accident. Appendix J identi"es three types of required tests:

1) Type A tests, intended to measure the primary containment overall integrated leakage rate;

2) Type B tests, intended to detect local leaks and to measure leakage across pressure-containing or leakage limiting boundaries (other than valves) for primary containment penetrations; and,

3) Type C tests, intended to measure CIV leakage rates.

Types B and C tests identify the vast majority of potential containment leakage paths. Type A tests identify the overall (integrated) containment leakage rate and serve to ensure continued leakage integrity of the containment structure by evaluating those structural parts of the containment not covered by Types B and C testing.

In 1995, 10 CFR 50, Appendix J, was amended to provide a performance-based Option B for the containment leakage testing requirements. Option B requires that test intervals for Type A, Type B, and Type C testing be determined by using a performance-based approach. Performance-based test intervals are based on consideration of the operating history of the component and resulting risk from its failure. The use of the term performance-based in 10 CFR 50, Appendix J refers to both the performance history necessary to extend test intervals as well as to the criteria necessary to meet the requirements of Option B.

Also, in 1995, Regulatory Guide (RG) 1.163, Performance-Based Containment Leak-Test Program, was issued. The RG endorsed NEI 94-01, Revision 0, with certain modi"cations and additions. Option B, in concert with RG 1.163 and NEI 94-01, Revision 0, allows licensees with a satisfactory Integrated Leak Rate Test (ILRT) performance history (i.e., two consecutive, successful Type A tests) to reduce the test frequency for the containment Type A (ILRT) test from three tests in 10 years to one test in 10 years. This relaxation was based on an NRC risk assessment contained in NUREG-1493, and Electric Power Research Institute (EPRI) TR-104285, both of which showed that the risk increase associated with extending the ILRT surveillance interval was very small. In addition to the 10-year ILRT interval, provisions for extending the test interval an additional 15 months were considered in the establishment of the intervals allowed by RG 1.163 and

Serial No.25-045 Docket No. 50-395, Page 4 of 22 NEI 94-01, but that this extension of interval should be used only in cases where refueling schedules have been changed to accommodate other factors.

In 2008, NEI 94-01, Revision 2-A, was issued. This document describes an acceptable approach for implementing the optional performance-based requirements of Option B to 10 CFR 50, Appendix J, subject to the limitations and conditions noted in Section 4.0 of the NRC Safety Evaluation (SE) on NEI 94-01.

NEI 94-01, Revision 2-A, includes provisions for extending Type A ILRT intervals to up to 15 years and incorporates the regulatory positions stated in RG 1.163. It delineates a performance-based approach for determining Type A, Type B, and Type C containment leakage rate surveillance testing frequencies. Justi"cation for extending test intervals is based on the performance history and risk insights.

In 2012, NEI 94-01, Revision 3-A, was issued. This document describes an acceptable approach for implementing the optional performance-based requirements of Option B to 10 CFR 50, Appendix J and includes provisions for extending Type A ILRT intervals to up to 15 years. NEI 94-01 has been endorsed as an acceptable methodology for complying with the provisions of 10 CFR Part 50, Appendix J, Option B, by RG 1.163 and NRC SEs dated June 25, 2008 and June 8, 2012. The regulatory positions stated in RG 1.163, as modi"ed by NRC SEs dated June 25, 2008 and June 8, 2012, are incorporated in NEI 94-01 Revision 3-A. It delineates a performance-based approach for determining Type A, Type B, and Type C containment leakage rate surveillance testing frequencies.

Justi"cation for extending test intervals is based on the performance history and risk insights. Extensions of Type B and Type C test intervals are allowed based upon completion of two consecutive periodic as found tests where the results of each test are within a licensees allowable administrative limits. Intervals may be increased from 30 months up to a maximum of 120 months for Type B tests (except for containment airlocks) and up to a maximum of 75 months for Type C tests. If a licensee considers extended test intervals of greater than 60 months for Type B or Type C tested components, the review should include the additional considerations of as found tests, schedule and review as described in NEI 94-01, Revision 3-A, Section 11.3.2.

NEI 94-01, Revision 3-A, Section 10.1, Introduction, concerning the use of test interval extensions in the deferral of Type B and Type C LLRTs, based on performance, states in part, that:

Consistent with standard scheduling practices for TS Required Surveillances, intervals of up to 120 months for the recommended surveillance frequency for Type B testing and up to 75 months for Type C testing given in this section may be extended by up to 25% of the test interval, not to exceed nine months.

Serial No.25-045 Docket No. 50-395, Page 5 of 22 Notes: For routine scheduling of tests at intervals over 60 months, refer to the additional requirements of Section 11.3.2.

Extensions of up to nine months (total maximum interval of 84 months for Type C tests) are permissible only for non-routine emergent conditions. This provision (nine-month extension) does not apply to valves that are restricted and/or limited to 30-month intervals in Section 10.2 (such as BWR MSIVs) or to valves held to the base interval (30 months) due to unsatisfactory LLRT performance.

The NRC has also provided the following concerning the extension of ILRT intervals to 15 years in NEI 94-01, Revision 3-A, NRC SE Section 4.0, Condition 2, which states, in part:

The basis for acceptability of extending the ILRT interval out to once per 15 years was the enhanced and robust primary containment inspection program and the local leakage rate testing of penetrations. Most of the primary containment leakage experienced has been attributed to penetration leakage and penetrations are thought to be the most likely location of most containment leakage at any time.

Current VCSNS 10 CFR 50, Appendix J Requirements 10 CFR 50, Appendix J was revised, eective October 26, 1995, to allow licensees to choose containment leakage testing under either Option A, Prescriptive Requirements, or Option B, Performance-Based Requirements. On October 2, 1996, the NRC issued Amendment No. 135 for VCSNS Unit 1, authorizing the implementation of 10 CFR 50, Appendix J, Option B for Types A, B, and C tests.

The amendment modi"ed the TS to replace the existing scheduling requirements for overall integrated and local containment leakage rate testing with a requirement to perform the testing in accordance with 10 CFR Part 50, Appendix J, Option B, Performance-Based Containment Leakage Rate Testing.

Current VCSNS Unit 1 TS 6.8.4.g requires that a program be established to comply with the containment leakage rate testing requirements of 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B. The program is required to be in accordance with the guidelines contained in NEI 94-01, Revision 2-A, as an acceptable method for complying with the provisions of Appendix J, Option B.

Serial No.25-045 Docket No. 50-395, Page 6 of 22 VCSNS 10 CFR 50, Appendix J, Option B Licensing History October 2, 1996 - License Amendment No. 135 VCSNS Amendment No. 135 modi"ed the TS to replace the prescriptive scheduling requirements for overall integrated and local containment leakage rate testing with a requirement to perform the testing in accordance with 10 CFR Part 50, Appendix J, Option B, Performance-Based Containment Leakage Rate Testing. Option B allows test scheduling to be adjusted based on past performance. The amendment established the TS 6.8.4.g, Containment Leakage Rate Testing Program, using the guidelines provided in RG 1.163 and NEI 94-01, Revision 0.

May 1, 2012 - License Amendment No. 189 VCSNS Amendment No. 189 revised TS 6.8.4.g, Containment Leakage Rate Testing Program, to re"ect a one-time extension of the Type A or containment ILRT interval requirement, under 10 CFR Part 50, Appendix J, Option B, from 120 months (10 years) to 130 months (10.9 years). The amendment allowed the next Type A ILRT to be performed within 130 months of the most recent Type A test at VCSNS, which was performed on October 15, 2003, but no later than August 15, 2014.

February 5, 2014 - License Amendment No. 194 VCSNS Amendment No. 194 revised TS 6.8.4.g, Containment Leakage Rate Testing Program, to re"ect a permanent extension of the Type A or containment ILRT interval requirement, under 10 CFR Part 50, Appendix J, Option B, from 10.9 years (130 months) to 15 years. The amendment revised TS 6.8.4.g to adopt NEI 94-01, Revision 3-A, as the implementation document, but exempted an extension of the Type C tests. The amendment allowed the next Type A ILRT to be performed within 15 years of the most recent Type A test at VCSNS, which had been performed on October 15, 2003, but no later than October 15, 2018.

June 28, 2018 - License Amendment No. 210 VCSNS Amendment 210 revised TS 6.8.4.g, Containment Leakage Rate Testing Program, by increasing the ILRT Peak Calculated Containment Internal Pressure for the design basis loss of coolant accident (Pa) from 45.1 pounds per square inch gauge (psig) to 46.0 psig. The amendment revised TS 6.8.4.g to remove the references to RG 1.163 and ANSI/ANS-56.8-2002 and replaced the reference to NEI 94-01, Revision 3-A, with NEI 94-01, Revision 2-A. The replacement of NEI

Serial No.25-045 Docket No. 50-395, Page 7 of 22 94-01, Revision 3-A with Revision 2-A was more appropriate since the Type C test extension was exempted in Amendment No. 194.

3.2 System Design and Operation Containment Building Description VCSNS Containment is provided by the Reactor Building, a reinforced concrete structure designed by Gilbert Associates, Inc. The Reactor Building is a post tensioned, reinforced concrete structure with an integral steel liner. The Reactor Building consists of a cylindrical wall, a shallow dome roof, and a foundation mat with a depressed incore instrumentation pit under the reactor vessel. The foundation mat and cylindrical wall are reinforced with conventional mild steel reinforcing. The cylindrical wall is prestressed in the vertical and horizontal directions by a post-tensioning system. The shallow dome roof is prestressed by a three-way post-tensioning system. The inside surface of the Reactor Building is lined with a carbon steel liner to ensure a high degree of leak tightness under operating and accident conditions.

Containment Penetrations and Attachments There are 2 personnel airlocks and one equipment hatch that penetrate the containment boundary. There is a 16-foot diameter equipment hatch, a 9-foot diameter personnel airlock, and a 5-foot diameter personnel emergency airlock. In the case of these penetrations, the barrel is solidly welded to the Reactor Building liner. The cover door on the equipment hatch is sealed to the barrel assembly with a double O-ring seal. Both the inside and outside doors of both personnel airlocks are sealed with double O-ring seals. The personnel airlocks also have operating shafts which penetrate the inner and outer barriers of these penetrations. These barrier penetrations are also sealed with double O-ring seals. The double O-ring seals are subjected to Type B leakage tests.

Each airlock design provides test connections on the atmosphere side of the atmosphere bulkhead for use in leak testing the entire airlock interspace at design pressure, Pa. For local leak testing, a test panel is located on the atmosphere side of the atmosphere bulkhead of each airlock. Separate test connections are provided on each test panel for individual pressurization between the double seals for all handwheel shafts and between the double seals for each door.

All Reactor Building penetrations are anchored to the concrete Reactor Building wall or foundation mat so that loads are transferred from the penetrations to the concrete. All penetrations satisfy the requirements of 10 CFR 50, Appendix J.

Serial No.25-045 Docket No. 50-395, Page 8 of 22 Penetrations are classi"ed into the following groups: piping penetrations, mechanical system penetrations, electrical system penetrations, and spare penetrations.

All piping penetrations consist of a sleeve around the outside of the piping. The piping is joined to the sleeve inside the Reactor Building by an attachment plate.

Outside the Reactor Building, piping is attached to the sleeve by an attachment plate or by a bellows assembly. The attachments at both the inside and outside ends of the sleeve create an interspace between the sleeve and piping. This interspace is tested to ensure that leak rate requirements are satis"ed. The bellows and sleeve are designed to withstand the containment design pressure and temperature. Each sleeve is integrally welded to a surrounding, thickened liner reinforcing plate. The weld between the sleeve and reinforcing plate is covered by a circular test channel which is used for testing the leak tightness of the weld.

Periodic Type C tests are conducted in accordance with 10 CFR 50, Appendix J, to determine the operability and leakage rate characteristics of valves serving an isolation function in the testable fluid systems lines penetrating the Reactor Building.

The Engineered Safety Features Actuation System (ESFAS) test circuitry provides the means for testing isolation valve operability.

3.3 Technical Analysis Primary Containment Leakage Rate Testing Program - Type B and Type C Testing Program VCSNS Types B and C testing program requires testing of electrical penetrations, airlocks, hatches, "anges, and containment isolation valves in accordance with 10 CFR 50, Appendix J, Option B and NEI 94-01, Revision 2-A. The results of the test program are used to demonstrate that proper maintenance and repairs are made on these components throughout their service life. The Types B and C testing program provides a means to protect the health and safety of plant personnel and the public by maintaining leakage from these components below appropriate limits.

In accordance with TS 6.8.4.g, the allowable maximum containment leakage rate (La) pathway total Types B and C leakage is 0.6 La where 0.6 La equals 176,832 standard cubic centimeters per hour (sccm) and La equals 294,705 sccm.

As discussed in NUREG-1493, Type B and Type C tests can identify the vast majority of all potential containment leakage paths. Type B and Type C testing will continue to provide a high degree of assurance that containment integrity is maintained.

Serial No.25-045 Docket No. 50-395, Page 9 of 22 A review of the Type B and Type C test results from 2014 through 2024 for VCSNS has shown substantial margin between the actual As-Found (AF) and As-Left (AL) outage summations and the regulatory requirements as described below:

The as-found minimum pathway leak rate average for VCSNS Unit 1 shows an average of 20.428% of 0.6 La with a high of 23.726% 0.6 La or 0.142 La.

The as-left maximum pathway leak rate average for VCSNS Unit 1 shows an average of 33.169% of 0.6 La with a high of 44.298% 0.6 La or 0.266 La.

, Table 2-1 provides LLRT data trend summaries for VCSNS since 2014, inclusive of the 2018 ILRT. This summary shows that there has been no As-Found failure that resulted in exceeding the TS 6.8.4.g limit of 0.6 La and demonstrates a history of successful tests. The As-Found minimum pathway summations represent the high quality of maintenance of Types B and C tested components, while the As-Left maximum pathway summations represent the eective management of the Containment Leakage Rate Testing Program by the program owner.

Type B and Type C Local Leak Rate Testing Program Implementation Review

, Table 2-2 identifies the components that have not demonstrated acceptable performance during the previous three outages for VCSNS.

Type B and Type C Component Performance Summary The percentage of the total number of VCSNS Unit 1 Type B tested components (70 total nozzles/airlocks associated with 61 penetrations) that are on 120-month extended performance-based test intervals is 81.4% (57 components associated with 48 penetrations).

The remaining Type B penetrations that are not on an extended test frequency are:

Used during refueling outages (RFO) and therefore must be AL tested each RFO subsequent to use (8 components, 11.4%),

AL tested each RFO to support FLEX requirements (2 components, 2.9%),

or Limited to a test frequency of 30 months per the Primary Containment Leakage Rate Testing Program (3 components, 4.3%).

Serial No.25-045 Docket No. 50-395, Page 10 of 22 The percentage of the total number of VCSNS Unit 1 Type C tested components (100 total valves associated with 49 penetrations) that are on 60-month extended performance-based test intervals is 66.0% (66 valves associated with 32 penetrations).

The remaining Type C penetrations not on a 60-month extended test frequency are:

On a 30-month frequency (resulting in a test every RFO) following valve replacement or major maintenance to re-establish their performance history of two satisfactory consecutive AF tests (9 valves associated with 4 penetrations identified in Attachment 2, Table 2-2, 9.0%),

Used or removed during RFOs to support FLEX or outage requirements (10 valves associated with 7 penetrations, 10.0%), or Not on an extended test frequency of 60 months due to limitations by another program (e.g., Inservice Testing, Relief Valve, Check Valve Condition Monitoring), even though they have met the performance requirements of two satisfactory consecutive AF test after the last Type C test (15 valves associated with 6 penetrations, 15.0%).

Therefore, the current Type B and Type C performance supports an allowance to extend to the Type C interval up to 75 months.

3.4 NRC Safety Evaluation Limitations and Conditions.

Limitations and Conditions Applicable to NEI 94-01, Revision 3-A The NRC staff found that the guidance in NEI 94-01, Revision 3, was acceptable for referencing by licensees in the implementation for the optional performance-based requirements of Option B to 10 CFR 50, Appendix J. However, the NRC staff identified two conditions on the use of NEI 94-01, Revision 3 (Reference NEI 94-01, Revision 3-A, NRC SE 4.0, Limitations and Conditions):

Topical Report Condition 1 NEI 94-01, Revision 3, is requesting that the allowable extended interval for Type C LLRTs be increased to 75 months, with a permissible extension (for non-routine emergent conditions) of nine months (84 months total). The staff is allowing the extended interval for Type C LLRTs be increased to 75 months with the requirement that a licensee's post-outage report include the margin between the Type B and Type C leakage rate summation and its regulatory limit. In addition, a

Serial No.25-045 Docket No. 50-395, Page 11 of 22 corrective action plan shall be developed to restore the margin to an acceptable level. The staff is also allowing the non-routine emergent extension out to 84-months as applied to Type C valves at a site, with some exceptions that must be detailed in NEI 94-01, Revision 3. At no time shall an extension be allowed for Type C valves that are restricted categorically (e.g., BWR MSIVs), and those valves with a history of leakage, or any valves held to either a less than maximum interval or to the base refueling cycle interval. Only non-routine emergent conditions allow an extension to 84 months.

Response to Condition 1:

Condition 1 presents three separate issues that are required to be addressed.

They are as follows:

ISSUE 1 - The allowance of an extended interval for Type C LLRTs of 75 months carries the requirement that a licensee's post-outage report include the margin between the Type B and Type C leakage rate summation and its regulatory limit.

ISSUE 2 - In addition, a corrective action plan shall be developed to restore the margin to an acceptable level.

ISSUE 3 - Use of the allowed 9-month extension for eligible Type C valves is only authorized for non-routine emergent conditions with exceptions as detailed in NEI 94-01, Revision 3-A, Section 10.1.

Response to Condition 1, ISSUE 1:

The post-outage report shall include the margin between the Type B and Type C Minimum Pathway Leak Rate (MNPLR) summation value, as adjusted to include the estimate of applicable Type C leakage understatement, and its regulatory limit of 0.6 La.

Response to Condition 1, ISSUE 2:

VCSNS will assess and monitor margin between the Type B and C MNPLR summation value, as adjusted to include the estimate of applicable Type C leakage understatement, included in the post-outage report and its regulatory limit of 0.6 La. This will include corrective actions to restore margin to an acceptable level, if required. The corrective action plan shall focus on those components which have contributed the most to the increase in the leakage summation value and the manner of timely corrective action, as deemed appropriate, that best focuses on the prevention of future component leakage performance issues to maintain an acceptable level of margin.

Serial No.25-045 Docket No. 50-395, Page 12 of 22 Response to Condition 1, ISSUE 3:

VCSNS will apply the 9-month allowable interval extension period only to eligible Type C components for non-routine emergent conditions. Such occurrences will be documented in the record of tests.

Topical Report Condition 2 The basis for acceptability of extending the ILRT interval out to once per 15 years was the enhanced and robust primary containment inspection program and the local leakage rate testing of penetrations. Most of the primary containment leakage experienced has been attributed to penetration leakage and penetrations are thought to be the most likely location of most containment leakage at any time.

The containment leakage condition monitoring regime involves a portion of the penetrations being tested each refueling outage, nearly all LLRTs being performed during plant outages. For the purposes of assessing and monitoring or trending overall containment leakage potential, the as found minimum pathway leakage rates for the just tested penetrations are summed with the as left minimum pathway leakage rates for penetrations tested during the previous 1 or 2 or even 3 refueling outages. Type C tests involve valves, which in the aggregate, will show increasing leakage potential due to normal wear and tear, some predictable and some not so predictable. Routine and appropriate maintenance may extend this increasing leakage potential. Allowing for longer intervals between LLRTs means that more leakage rate test results from farther back in time are summed with fewer just tested penetrations and that total used to assess the current containment leakage potential. This leads to the possibility that the LLRT totals calculated understate the actual leakage potential of the penetrations. Given the required margin included with the performance criterion and the considerable extra margin most plants consistently show with their testing, any understatement of the LLRT total using a 5-year test frequency is thought to be conservatively accounted for.

Extending the LLRT intervals beyond 5 years to a 75-month interval should be similarly conservative provided an estimate is made of the potential understatement and its acceptability determined as part of the trending specified in NEI 94-01, Revision 3, Section 12.1.

When routinely scheduling any LLRT valve interval beyond 60-months and up to 75-months, the primary containment leakage rate testing program trending or monitoring must include an estimate of the amount of understatement in the Type B and C total leakage, and must be included in a licensee's post-outage report.

The report must include the reasoning and determination of the acceptability of the extension, demonstrating that the LLRT totals calculated represent the actual leakage potential of the penetrations.

Serial No.25-045 Docket No. 50-395, Page 13 of 22 Response to Condition 2:

Condition 2 presents two (2) separate issues that are required to be addressed as follows:

ISSUE 1 - Extending the LLRT intervals beyond 5 years to a 75-month interval should be similarly conservative provided an estimate is made of the potential understatement and its acceptability determined as part of the trending specified in NEI 94-01, Revision 3-A, Section 12.1.

ISSUE 2 - When routinely scheduling any LLRT valve interval beyond 60 months and up to 75 months, the primary containment leakage rate testing program trending or monitoring must include an estimate of the amount of understatement in the Type B and C total, and must be included in a licensee's post-outage report. The report must include the reasoning and determination of the acceptability of the extension, demonstrating that the LLRT totals calculated represent the actual leakage potential of the penetrations.

Response to Condition 2, ISSUE 1:

The change in going from a 60-month extended test interval for Type C tested components to a 75-month interval, as authorized under NEI 94-01, Revision 3-A, represents an increase of 25% in the LLRT periodicity. As such, VCSNS will conservatively apply a potential leakage understatement adjustment factor of 1.25 to the actual As Left leak rate, which will increase the As Left leakage total for each Type C component currently on greater than a 60-month test interval up to the 75-month extended test interval. This will result in a combined conservative Type C total for all 75-month LLRTs being carried forward and will be included whenever the total leakage summation is required to be updated (either while online or following an outage).

Response to Condition 2, ISSUE 2:

The potential leakage understatement adjusted leak rate total for those Type C components being tested on greater than a 60-month test interval up to the 75-month extended test interval will be summed with the non-adjusted total of those Type C components being tested at less than or equal to a 60-month test interval, and the total of the Type B tested components. The margin between the MNPLR and the regulatory limit of 0.6 La will be assessed and monitored and included as part of the post-outage report. This will include corrective actions to restore margin to an acceptable level, if required. The corrective action plan shall focus on those components which have contributed the most to the increase in the leakage summation value and the manner of timely corrective action, as deemed appropriate, that best focuses on the prevention of future component leakage performance issues.

Serial No.25-045 Docket No. 50-395, Page 14 of 22 In addition to Condition 1, ISSUES 1 and 2, which deal with the MNPLR Type B and C summation margin, NEI 94-01, Revision 3-A, also has a margin-related requirement as contained in Section 12.1, Report Requirements.

A post-outage report shall be prepared presenting results of the previous cycles Type B and Type C tests, and Type A, Type B and Type C tests, if performed during that outage. The technical contents of the report are generally described in ANSI/ANS-56.8-2002 and shall be available on-site for NRC review. The report shall show that the applicable performance criteria are met and serve as a record that continuing performance is acceptable. The report shall also include the combined Type B and Type C leakage summation, and the margin between the Type B and Type C leakage rate summation and its regulatory limit. Adverse trends in the Type B and Type C leakage rate summation shall be identified in the report and a corrective action plan developed to restore the margin to an acceptable level.

In the event an adverse trend in the aforementioned potential leakage understatement adjusted Type B and C summation is identified at VCSNS, an analysis and determination of a corrective action plan will be prepared to restore the associated margin to an acceptable level. The corrective action plan will focus on components that have contributed the most to the adverse trend in the leakage summation value and the manner of timely corrective action, as deemed appropriate, that best focuses on the prevention of future component leakage performance issues.

At VCSNS, an adverse trend is defined as three (3) consecutive increases in the final pre-mode change Type B and C MNPLR leakage summation values, as adjusted to include the estimate of applicable Type C leakage understatement, as expressed in terms of La.

3.5 Conclusion Adoption of NEI 94-01, Revision 3-A NEI 94-01, Revision 3-A, dated July 2012, describes an NRC-accepted approach for implementing the performance-based requirements of 10 CFR 50, Appendix J, Option B. It incorporated the regulatory positions stated in RG 1.163 and includes provisions for extending Type C test intervals to 75 months. NEI 94-01, Revision 3-A delineates a performance-based approach for determining Type A, Type B, and Type C containment leakage rate surveillance test frequencies. VCSNS proposes the adoption of the guidance of NEI 94-01, Revision 3-A, as well as the Limitations and Conditions of NEI 94-01, Revision 2-A, for the VCSNS 10 CFR 50, Appendix J testing program plan.

Serial No.25-045 Docket No. 50-395, Page 15 of 22

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements and Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.

10 CFR 50.54(o) requires primary reactor containments for water-cooled power reactors to be subject to the requirements of Appendix J to 10 CFR 50, Primary Reactor Containment Leakage Rate Testing for Water-Cooled Power Reactors.

Appendix J speci"es containment leakage testing requirements, including the types required to ensure the leak-tight integrity of the primary reactor containment and systems and components which penetrate the containment. In addition, Appendix J discusses leakage rate acceptance criteria, test methodology, frequency of testing, and reporting requirements for each type of test.

The adoption of the Option B performance-based containment leakage rate testing for Type A, Type B, and Type C testing did not alter the basic method by which Appendix J leakage rate testing is performed; however, it did alter the frequency at which Type A, Type B, and Type C containment leakage tests must be performed.

Under the performance-based option of 10 CFR 50, Appendix J, the test frequency is based upon an evaluation that reviewed as found leakage history to determine the frequency for leakage testing which provides assurance that leakage limits will be maintained. The change to the Type A test frequency did not directly result in an increase in containment leakage. Similarly, the proposed change to the Type C test frequencies will not directly result in an increase in containment leakage.

The NRC sta reviewed NEI 94-01, Revision 3, and determined that it described an acceptable approach for implementing the optional performance-based requirements of Option B to 10 CFR 50, Appendix J, as modi"ed by the conditions and limitations summarized in Section 4.0 of the associated SE. This guidance included provisions for extending Type C LLRT intervals up to 75 months. Type C testing ensures that individual CIVs are essentially leak tight. In addition, aggregate Type C leakage rates support the leakage tightness of primary containment by minimizing potential leakage paths. The NRC sta, therefore, found that this guidance, as modi"ed to include two limitations and conditions, was acceptable for referencing by licensees proposing to amend their TS in regards to containment leakage rate testing. Any applicant may reference NEI 94-01, Revision 3, as modi"ed by the associated SE and approved by the NRC, and the conditions and limitations speci"ed in NEI 94-01, Revision 2-A, dated October 2008, in a licensing action to satisfy the requirements of Option B to 10 CFR 50, Appendix J.

Serial No.25-045 Docket No. 50-395, Page 16 of 22

4.2 Precedents

This LAR is similar in nature to the following license amendments for extending the Type C test frequency to 75 months as previously authorized by the NRC in the associated referenced SERs:

Grand Gulf Nuclear Station, Unit 1 (ML16011A247)

Surry Power Station, Unit 1 (ML14148A235)

Donald C. Cook Nuclear Plant, Unit 1 (ML15072A264)

Beaver Valley Power Station, Unit Nos. 1 and 2 (ML15078A058)

Calvert Clis Nuclear Power Plant, Unit Nos. 1 and 2 (ML1514A661)

Peach Bottom Atomic Power Station, Units 2 and 3 (ML15196A559)

Comanche Peak Nuclear Power Plant, Unit 1 (ML15309A073)

Catawba Nuclear Station, Unit 1 (ML16229A113)

H. B. Robinson Steam Electric Plant, Unit No. 2 (ML16201A195)

Quad Cities Nuclear Power Station, Unit 1 (ML17311A162)

Dresden Nuclear Power Station, Units 2 and 3 (ML18137A271)

McGuire Nuclear Station, Unit 1 (ML18009A842)

Vogtle Electric Generating Plant, Unit 1 (ML18263A039)

Braidwood Station, Units 1 and 2 (ML20149K698)

Byron Station, Units 1 and 2 (ML20149K698) 4.3 No Significant Hazards Consideration Dominion Energy South Carolina (DESC) proposes to amend the Technical Speci"cations (TS) for Virgil C. Summer Nuclear Station (VCSNS), Unit 1 to allow extension of the Type C test intervals. The extension is based on the adoption of the Nuclear Energy Institute (NEI) 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, Revision 3-A.

Speci"cally, the proposed change revises VCSNS TS 6.8.4.g by replacing the reference to NEI 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J, Revision 2-A with a reference to NEI 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J, Revision 3-A and the conditions and limitations speci"ed in NEI 94-01, Revision 2-A.

DESC has evaluated whether or not a signi"cant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below:

Serial No.25-045 Docket No. 50-395, Page 17 of 22

1.

Does the proposed amendment involve a signi"cant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed activity involves the revision of the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Technical Speci"cation (TS) 6.8.4.g, Containment Leakage Rate Testing Program, to allow the extension of the Type C test interval to 75 months. Per the guidance provided in Nuclear Energy Institute (NEI) 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J, Revision 3-A, the current Type C test interval of 60 months for selected components would be extended on a performance basis to no longer than 75 months. Extensions of up to nine months for Types A, B, and C tests are permissible only for non-routine emergent conditions.

The proposed interval extensions do not involve either a physical change to the plant or a change in the manner in which the plant is operated or controlled.

The containment is designed to provide an essentially leak tight barrier against the uncontrolled release of radioactivity to the environment for postulated accidents. As such, the containment and the testing requirements invoked to periodically demonstrate the integrity of the containment exist to ensure the plant's ability to mitigate the consequences of an accident, and do not involve the prevention or identi"cation of any precursors of an accident.

Therefore, the proposed changes do not result in a signi"cant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or dierent kind of accident from any accident previously evaluated?

Response: No.

The proposed amendment to the VCSNS Unit 1 TS 6.8.4.g, Containment Leakage Rate Testing Program, involves the extension of the VCSNS, Unit 1 Type C test interval to 75 months. The containment and the testing requirements to periodically demonstrate the integrity of the containment exist to ensure the plants ability to mitigate the consequences of an accident.

The proposed change does not involve a physical modi"cation to the plant (i.e.,

no new or dierent type of equipment will be installed) nor does it alter the

Serial No.25-045 Docket No. 50-395, Page 18 of 22 design, con"guration, or change the manner in which the plant is operated or controlled beyond the standard functional capabilities of the equipment.

Therefore, the proposed change does not create the possibility of a new or dierent kind of accident from any previously evaluated.

3.

Does the proposed change involve a signi"cant reduction in a margin of safety?

Response: No.

The proposed amendment to the VCSNS Unit 1 TS 6.8.4.g involves the extension of the VCSNS Type C test interval to 75 months. This amendment does not alter the manner in which safety limits, limiting safety system set points, or limiting conditions for operation are determined. The speci"c requirements and conditions of the TS Leak Rate Testing Program exist to ensure that the degree of containment structural integrity and leak-tightness that is considered in the plant safety analysis is maintained. The overall containment leak rate limit speci"ed by TS is maintained.

The proposed change involves the extension of the interval between Type C tests for VCSNS Unit 1. The proposed surveillance interval extension is bounded by the 75-month Type C test interval currently authorized within NEI 94-01, Revision 3-A. Industry experience supports the conclusion that Type B and C testing detects a large percentage of containment leakage paths and that the percentage of containment leakage paths that are detected only by Type A testing is small. The containment inspections performed in accordance with Option B to 10 CFR 50, Appendix J and the overlapping inspection activities performed as part of ASME Section Xl, and the TS serve to provide a high degree of assurance that the containment would not degrade in a manner that is detectable only by Type A testing. The combination of these factors ensures that the margin of safety in the plant safety analysis is maintained. The design, operation, testing methods, and acceptance criteria for Types A, B, and C containment leakage tests speci"ed in applicable codes and standards would continue to be met, with the acceptance of this proposed change, since these are not aected by changes to the Type C test intervals.

Therefore, the proposed changes do not involve a signi"cant reduction in a margin of safety.

Serial No.25-045 Docket No. 50-395, Page 19 of 22 Based on the above, DESC concludes that the proposed amendment does not involve a signi"cant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a "nding of no signi"cant hazards consideration is justi"ed.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as de"ned in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve: (i) a signi"cant hazards consideration, (ii) a signi"cant change in the types or signi"cant increase in the amounts of any euent that may be released osite, or (iii) a signi"cant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Serial No.25-045 Docket No. 50-395, Page 20 of 22 6.0 References

1.

NEI 94-01, Revision 3-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, dated July 2012.

2.

NEI 94-01, Revision 2-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, dated October 2008.

3.

ANSI/ANS-56.8-2002, Containment System Leakage Testing Requirements, dated November 27, 2002.

4.

NRC Regulatory Guide 1.163, Revision 0, Performance-Based Containment Leak-Test Program, dated September 1995.

5.

10 CFR Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors.

6.

NEI 94-01, Revision 0, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, dated July 26, 1995.

7.

NUREG-1493, Performance-Based Containment Leak-Test Program, dated September 1995.

8.

EPRI TR-104285, Risk Impact Assessment of Revised Containment Leak Rate Test Intervals, dated August 1994.

9.

Letter from M. J. Maxin (NRC) to J. C. Butler (NEI), Final Safety Evaluation for Nuclear Energy Institute (NEI) Topical Report (TR) 94-01, Revision 2, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J and Electric Power Research Institute (EPRI) Report No. 1009325, Revision 2, August 2007, Risk-Impact Assessment of Extended Integrated Leak Rate Testing Intervals (TAC No. MC9663), dated June 25, 2008 (ML081140105).

10. Letter from S. Bahadur (NRC) to B. Bradley (NEI), Final Safety Evaluation of Nuclear Energy Institute (NEI) Report, 94-01, Revision 3, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J (TAC No. ME2164), dated June 8, 2012 (ML121030286).

11. EPRI 1009325, Revision 2, Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals, dated August 2007.

12. Letter from A.R. Johnson (NRC) to G.J. Taylor (SCE&G), Issuance of Amendment No. 135 to Facility Operating License No. NPF-12 Regarding 10 CFR 50, Appendix J, Option B, Performance-Based Requirements - Virgil C.

Summer Nuclear Station, Unit No. 1 (TAC No. M95222), dated October 2, 1996 (ML012270146).

Serial No.25-045 Docket No. 50-395, Page 21 of 22

13. Letter from R.E. Martin (NRC) to T.D. Gatlin (SCE&G), Virgil C. Summer Nuclear Station, Unit 1 - Issuance of Amendment Extending Integrated Leak Rate Test Interval (TAC No. ME7344), dated May 1, 2012 (ML12121A034).

14. Letter from S. Williams (NRC) to T.D. Gatlin (SCE&G), Virgil C. Summer Nuclear Station, Unit 1 - Issuance of Amendment Extending Integrated Leak Rate Test Interval (TAC No. MF1385), dated February 5, 2014 (ML13326A204).

15. Letter from S.A. Williams (NRC) to T.D. Gatlin (SCE&G), Virgil C. Summer Nuclear Station, Unit 1 - Issuance of Amendment RE: Integrated Leak Rate Test Peak Calculated Containment Internal Pressure Change (EPID L-2017-LLA-0348), dated June 28, 2018 (ML18141A668).

16. Letter from J.S. Kim (NRC) to Vice President of Operations (Entergy), Grand Gulf Nuclear Station, Unit 1 - Issuance of Amendment RE: Revision of Technical Speci"cations for Containment Leak Rate Testing (CAC No.

MF6310), dated February 17, 2016 (ML16011A247).

17. Letter from S. Williams (NRC) to D.A. Heacock (Virginia Electric and Power),

Surry Power Station, Unit 1 - Issuance of Amendment Regarding the Containment Type A and Type C Leak Rate Tests (TAC Nos. MF2612 and MF2613), dated July 3, 2014 (ML14148A235).

18. Letter from A.W. Dietrich (NRC) to L.J. Weber (Indiana Michigan Power),

Donald C. Cook Nuclear Plant, Unit 1 - Issuance of Amendments Re:

Containment Leakage Rate Testing Program (TAC Nos. MF3568 and MF3569), dated March 30, 2015 (ML15072A264).

19. Letter from T.A. Lamb (NRC) to E.A. Larson (FirstEnergy), Beaver Valley Power Station, Unit Nos. 1 and 2 - Issuance of Amendment Re: License Amendment Request to Extend Containment Leakage Rate Test Frequency (TAC Nos. MF3985 and MF3986), dated April 8, 2015 (ML15078A058).

20. Letter from A.N. Chereskin (NRC) to G.H. Gellrich (Exelon), Calvert Clis Nuclear Power Plant, Unit Nos. 1 and 2 - Issuance of Amendments Re:

Extension of Containment Leakage Rate Testing Frequency (TAC Nos.

MF4898 and MF4899), dated July 16, 2015 (ML15154A661).

21. Letter from R.B. Ennis (NRC) to B.C. Hanson (Exelon), Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments Re: Extension of Type A and Type C Leak Rate Test Frequencies (TAC Nos. MF5172 and MF5173),

(ML15196A559).

Serial No.25-045 Docket No. 50-395, Page 22 of 22

22. Letter from B. Singal (NRC) to R. Flores (Luminant), Comanche Peak Nuclear Power Plant, Unit 1 - Issuance of Amendments Re: Technical Speci"cation Change for Extension of the Integrated Leak Rate Test Frequency from 10 to 15 Years (CAC Nos. MF5621 and MF5622), dated December 30, 2015 (ML15309A073).

23. Letter from M.D. Orenak (NRC) to K. Henderson (Duke Energy), Catawba Nuclear Station, Unit 1 - Issuance of Amendments Regarding Extension of the Containment Integrated Leak Rate Test Intervals (CAC Nos. MF7265 and MF7266), dated September 12, 2016 (ML16229A113).

24. Letter from D.J. Galvin (NRC) to R.M. Glover (Duke Energy), H. B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendment to Extend Containment Leakage Rate Test Frequencies (CAC No. MF7102), dated October 11, 2016 (ML16201A195).

25. Letter from K.J. Green (NRC) to B.C. Hanson (Exelon), Quad Cities Nuclear Power Station, Unit 1 - Issuance of Amendments Regarding Permanent Extension of Type A and Type C Leak Rate Test Frequencies (CAC Nos.

MF9675 and MF9676; EPID L-2017-LLA-0220) (RS-17-051), dated December 1, 2017 (ML17311A162).

26. Letter from R.S. Haskell, II (NRC) to B.C. Hanson (Exelon), Dresden Nuclear Power Station, Units 2 and 3 - Issuance of Amendments Regarding Permanent Extension of Type A and Type C Leak Rate Test Frequencies (CAC Nos.

MF9687 and MF9688; EPID L-2017-LLA-0228) (RS-17-060), dated June 29, 2018 (ML18137A271).

27. Letter from M. Mahoney (NRC) to T.D. Ray (Duke Energy), McGuire Nuclear Station, Unit 1 - Issuance of Amendments to Extend the Containment Type A Leak Rate Test Frequency to 15 Years and Type C Leak Rate Test Frequency to 75 Months (CAC Nos. MF9020 and MF9021; EPID L-2016-LLA-0032),

dated January 31, 2018 (ML18009A842).

28. Letter from M. Orenak (NRC) to C.A. Gayheart (Southern Nuclear), Vogtle Electric Generating Plant, Unit 1, Issuance of Amendments to Extend the Containment Type A Leak Rate Test Frequency to 15 Years and Type C Leak Rate Test Frequency to 75 Months (CAC Nos. MG0240 and MG0241; EPID L-2017-LLA-0295), dated October 29, 2018 (ML18263A039).

29. Letter from J.S. Wiebe (NRC) to B.C. Hanson (Exelon), Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 215, 215, 219, and 219 RE: Permanent Extension of Type A and Type C Containment Leak Rate Test Frequencies (EPID L-2019-LLA-0208), dated September 10, 2020 (ML20149K698).

Serial No.25-045 Docket No. 50-395 LOCAL LEAK RATE TEST DATA TREND

SUMMARY

AND PROGRAM IMPLEMENTATION REVIEW Dominion Energy South Carolina, Inc.

Virgil C. Summer Nuclear Station Unit 1

Serial No.25-045 Docket No. 50-395, Page 1 of 4 Table 2-1: Types B and C LLRT Combined As-Found/As-Left Trend Summary Year 2014 2015 2017 2018 2020 2021 2023 2024 RFO RF-21 RF-22 RF-23 RF-24 RF-25 RF-26 RF-27 RF-28 AF Min Path (sccm) 30,652 33,003 28,816 40,609 41,955 35,093 41,735 37,118 Fraction of 0.6 La

(%)

17.3 18.7 16.3 23.0 23.7 19.8 23.6 21.0 Fraction of La 0.104 0.112 0.098 0.138 0.142 0.119 0.142 0.126 AL Max Path (sccm) 57,630 55,322 47,713 61,328 58,580 53,859 78,334 56,457 Fraction of 0.6 La

(%)

32.6 31.3 27.0 34.7 33.1 30.5 44.3 31.9 Fraction of La 0.196 0.188 0.162 0.208 0.199 0.183 0.266 0.192 AL Min Path (sccm) 30,410 30,085 27,845 42,459 39,073 36,135 40,575 36,467 Fraction of 0.6 La

(%)

17.2 17.0 15.7 24.0 22.1 20.4 22.9 20.6 Fraction of La 0.103 0.102 0.094 0.144 0.133 0.123 0.138 0.124

Serial No.25-045 Docket No. 50-395, Page 2 of 4 Table 2-2: Types B and C LLRT Program Implementation Review Component

[Penetration No.]

As-Found (sccm)

Admin Limit (sccm)

As-Left (sccm)

Cause of Failure Corrective Action Scheduled Interval 2021 RF-26 XVC02661-IA RB IA Supply Header Check Valve

[XRP0311]

2,420 2,015 1,924 Corrosion on Valve Internals Clean valve internals Interval reset to baseline XVC09689-CC / XVG09605-CC RB CC Return Header Isolation Valve Bypass Check Valve /

RB CC Return Header Isolation Valve

[XRP0330]

> 20,000 2,920 1,443 XVC09689-CC Valve Internals (1)

Interval remained on baseline NOTES:

(1) Following failed AF LLRT, opened valve and cleaned out debris from between valve seat and disc. AL LLRT performed and leakage measured at 8,100 sccm. Re-opened valve and "ushed both the inlet/outlet piping associated with the valve.

Serial No.25-045 Docket No. 50-395, Page 3 of 4 Table 2-2: Types B and C LLRT Program Implementation Review (continued)

Component

[Penetration No.]

As-Found (sccm)

Admin Limit (sccm)

As-Left (sccm)

Cause of Failure Corrective Action Scheduled Interval 2023 RF-27 XVC02913-SA RB SA Header Check Valve

[XRP0310]

> 20,000 2,015 38.9 Corrosion on Valve Internals Clean valve internals Interval remained on baseline XVC02661-IA RB IA Supply Header Check Valve

[XRP0311]

2,420 2,015 1,960 Corrosion on Valve Internals Clean valve internals Interval remained on baseline XVX09365B-SS RCS Loop B Hot Leg Sample Header Isolation Valve

[XRP0314]

3,068 1,810 4,600 Not Determined (2)

Interval remained on baseline XVC09689-CC / XVG09605-CC RB CC Return Header Isolation Valve Bypass Check Valve /

RB CC Return Header Isolation Valve

[XRP0330]

5,260 2,920 9,900 XVG09605-CC Valve Actuator (3)

Interval remained on baseline NOTES:

(2) Replaced valve disc and cleaned interior of valve. AL LLRT performed and leakage measured at 4,600 sccm. Evaluated for continued service. A Work Order was written to cut out and weld in replacement valve.

(3) During RF-27, modi"cation VC-22-00005 implemented to replace swing-check XVC09689-CC with a soft-seated piston-check. Following modi"cation, AL LLRT performed with XVC09689-CC/XVG09605-CC leakage measured at 13,520 sccm. No internal valve work on XVG09605-CC was performed during RF-27 and troubleshooting con"rmed XVG09605-CC actuator was source of leakage. Corrective maintenance to replace XVG09605-CC stem nut completed and AL LLRT Retest performed with XVC09689-CC/XVG09605-CC leakage measured at 9,900 sccm. Evaluated for continued service. XVG09605-CC recommended for MOV actuator rebuild in RF-28.

Serial No.25-045 Docket No. 50-395, Page 4 of 4 Table 2-2: Types B and C LLRT Program Implementation Review (continued)

Component

[Penetration No.]

As-Found (sccm)

Admin Limit (sccm)

As-Left (sccm)

Cause of Failure Corrective Action Scheduled Interval 2024 RF-28 XVC09689-CC / XVG09605-CC RB CC Return Header Isolation Valve Bypass Check Valve /

RB CC Return Header Isolation Valve

[XRP0330]

(4) 2,920 757 (4)

(4)

Interval remained on baseline NOTES:

(4) AF LLRT was not performed on XVG09605-CC during RF-28 prior to disassembling the valve for inspection and refurbishing the MOV actuator due to scheduling constraints and challenges with the performance of STP-215.004. Following maintenance on XVG09605-CC, AL LLRT performed with XVC09689-CC/XVG09605-CC leakage measured at 757 sccm.

Serial No.25-045 Docket No. 50-395 MARKED-UP TECHNICAL SPECIFICATION PAGES Dominion Energy South Carolina, Inc.

Virgil C. Summer Nuclear Station Unit 1

Serial No.25-045 Docket No. 50-395, Page 1 of 3 No Change on Page - For Information Only ADMINISTRATIVE CONTROLS

d.

Critical operation of the unit shall not be resumed until authorized by the Commission.

6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:

a.

The applicable procedures recommended in Appendix "A"' of Regulatory Guide 1.33, Revision 2, February 1978.

b.

Refueling operations.

c.

Surveillance and test activities of safety-related equipment.

d.

Security Plan.

e.

Emergency Plan.

I.

PROCESS CONTROL PROGRAM.

g.

OFF SITE DOSE CALCULATION MANUAL.

h.

Effluent and environmental monitoring program using the guidance in Regulatory Guide 4.15, Revision 1, February 1979.

6.8.2 DELETED 6.8.3 NOT USED.

6.8.4 The following programs shall be established, implemented and maintained:

a.

b.

Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment tllat could contain lligllly radioactive nuids during a serious transient or accident to as low as practical levels. The systems include tile chemical and volume control, letdown, safety injection, residual heat removal, nuclear sampling, liquid radwaste handling, gas radwaste handling and reactor building spray system. Tile program sllall include tile fotlowing:

1)

Preventive maintenance and periodic visual inspection requirements, and

2)

Integrated leak test requirements for each system at refueling cycle intervals or less.

ln 4 Plant Radiation Monitoring

1)

Training of personnel,

2)

Procedures for monitoring, and

3)

Provisions for maintenance of sampling and analysis equipment.

SUMMER - UNIT 1 6-11 Amendment No. 1g, 4Q, 7;!, ?Q, 117, 130, 188, 199

Serial No.25-045 Docket No. 50-395, Page 2 of 3 ADMINISTRATIVE CONTROLS

f.

Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide (1) representative measures of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The program shall (1) be contained in the ODCM, (2) conform to the guidance of Appendix I to 1 0 CFR Part SO, and (3) include the following:

1)

Monitoring, sampling, analysis, and reporting of radiation and radionuclid'es in the environment in accordance with the methodology and parameters in the ODCM;

2)

A Land Use Census to ensure that changes in the use of areas at and beyond the site boundary are identified and that modifications to the monitoring program are made if required by the results of the census; and

3)

Participation in an Inter-laboratory Comparison Program to ensure that independent checks on the precision and accuracy of measurements of radioactive materials in environmental sample matrices are pertormed as part of the quality assurance program for environmental monitoring.

g.

Containment Leakage Rate Testing Program the guidelines contained in NEI 94-01 "Industry Guideline for Implementing Pertormance.Based Option of 1 0CFRS0, Appendix J,"

Revision 3*A, dated July 2012, and the conditions and limitations specified in NEI 94.01, Revision 2-A, dated October 2008.

A program shall be established to implement leakage rate testing of the containment system as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with ~IEI 94 Q1, ~oirisieA 2 A 1 *industry CwiEleliA06 tor IAlplOMOAtiAg P:olioFMaACO Based Option of 10 CFR Part so, Appendix,,.

9 eteber 2998.

The peak calculated containment internal pressure for the design basis loss of coolant accident. P,, is 46.0 psig.

The maximum allowable containment leakage rate, L.,, at P.,, is 0.20 percent by weight of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Leakage rate acceptance criteria are:

1)

Containment overall leakage rate acceptance criterion is !f 1.0 L.,.

During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are !f 0.60 L., for the combined Type 8 and Type C tests, and !f 0.75 L., for Type A tests; SUMMER - UNIT 1 6-12b Amendment No.1Q4, 117, 139, 135, 189, 191, 210

Serial No.25-045 Docket No. 50-395, Page 3 of 3 No Change on Page - For Information Only ec A0MINISTRATIVE COt-lTROLS g,

Containment L@akaw Bate Testing Program {Continued)

2)

Air lock testing acceptance criteria are:

a.

OveraJI air lock leakage rate is s 0.1 O l, when tested at ;z: P **

b.

For each door, leakage rato Is s 0.01 L, when pressurized to i?: 8.0 pslg for at least 3 minutes.

• The-provisions of Specrficatioo,4.0.2 do not apply to the tes1 frequencies specified in the Containment Leakage Rate TeStir'lg Pn,gram.

The provisions of Specification 4,0,3 arc applicable to the Containment Leakage Rate Testing Program.

h.

Containment loservir& lnsptetjoo Pmoram This program provides OC>f!lrols for monitoring containment vessel structural integrity including routine inspec:tiooS and tests to identify degradation and oorrective actions if degradation is found. The Containment lnservioe ln5Pection Program. inspection frequencies and aooeptance aiteria shall be in aocordance with 10CFR50.55a as modified by approved exemptions. Predicted ift~tf forces shall be determined consistent with the recommendations of Regulatory Guide 1.35.1, Revision 3 dated July 1990.

Any degradatiOn exe&eding the acoeptanoe criteria of the containment structure detected during the tests required by the Containment 11'\\Service lnspeC1ion Program shall unde"9(> an engineering evaluation within 60 days of the compJetion of the inspection surveillance. The resutts of the engineering evaluation shall be reported to the NAC within an additional 30 Clays of the time the evaluation is completed. The report shall include the cause of the condition that doBS not meet the acx:eptance criteria, the acceptability of 1he concrete eonta.inma.nt without repair of th& item, whether or not repair or replacement is required and, 11 required, the ex,ent. method, and completion of necessary repairs. and the eXlent, nature, and frequency of additional examinations.

In addition, any significant degradation which seriously challenges containment operability found during the inspection shatl be reponed to the NRC in aocordance with Technical Specification 6.9.2 within 30 days. The report shall inciude the description of degradation. operability determination. rC>CK cause determination, and corrective actions taken.

SUMMER

• UNIT 1 6,12c Amendment No.~148 Revised by NRC Letter dated August 2, 2001

Serial No.25-045 Docket No. 50-395 REVISED (CLEAN) TECHNICAL SPECIFICATIONS PAGE Dominion Energy South Carolina, Inc.

Virgil C. Summer Nuclear Station

Serial No.25-045 Docket No. 50-395, Page 1 of 1 Revised Technical Specification Page AD I ISTRATIVECONTROLS

f.

g.

Radiological Environmen nitomq Program A progam sha be provided o monita-raciation and radionudides *n the en

• ons of the plant The program shall provide (1) represen ative measu-es of radoactivity *n the highest poten *a1 exposll"e pa ys, and (2) erification of the accuracy of the effl ent morf oring program and modeling o en

• mental e sure p ys. The program shall ( ) be contained in the OOC, (2) con om, to the guidance of Appendi I o 0 CFR Part SO, and (3)

• dude the foll

1)

• oring, sarr~>l"ng, re

• ng of radiation and

2)

3) radionucr in e en *ron and parameters in the OOC acoordance *th the methodology A Land Use Census to ensure that changes *n the use of areas a beyond the site boundary are identi and tha modifications to the mon

• oring program are made if required by the r; of the census; and Participa *

• an Inter ory Comparison Pr(9'am o ure tha independe checks on the precision and accuracy of measureme of rad"toactive materials

• en

• rormental sample matrices are perfooned as part of the q ity assurance program fa-e *ronme I

mon* oring.

age Rae Testing Proqam A progam I be established to implemen leakage rate

• ng o the oo inment system as req *red by 0 CFR 50.54(0) and 0 CFR SO,

.Append"tx J, Option B, as modified by approved exemptions. This pr~

shall be in accordance *th the gu*

con *nec1 in 8 1 ndustry Guideline fa-mplementing Performance-Based Option of OCFRSO, Appendix J,- R

• ion 3-dated July 20 2, and conditions and limi tions specified in 94-01,

• *on 2-dated October 2008.

The peak calculated oontainmen internal pressure fa-the desqi basis loss of ooaant accide P~, is 46.0 psig.

The nlaXim.Jm all con ainme ge ra e, ~. at P,

• 0.20 percent by ight of the co

• nment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Leakage ra e acceptance criteria are:

1)

Contairvnen o rail leakage rate acceptance criterion is S.0 ~

During the first un

• startup f

• ng testing in accordance w

• program, the le age ra e acceptance crit *a are S 0.60 fa-the combi ed Type Band Type C ests, and S 0.75 fa-Type Ates

• SU ER-IT 1 6-12b Amendm No.104, 117, 130, 135, 139, 194, 210,