ML19015A243

Plan for the In-Office Regulatory Audit Regarding the Subsequent License Renewal Application Review (EPID Nos. L-2018-RNW-0023 and L-2018-RNW-0024)

ML19015A243
Person / Time
Site:	Surry
Issue date:	01/22/2019
From:	Sayoc E NRC/NRR/DMLR/MRPB
To:	Stoddard D Dominion Energy Virginia, Virginia Electric & Power Co (VEPCO)
Sayoc E
References
EPID L-2018-RNW-0023, EPID L-2018-RNW-0024
Download: ML19015A243 (8)

Text

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January 22, 2019 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd Glen Allen, VA 23060-6711

SUBJECT:

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

Dear Mr. Stoddard,

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

The NRC plans to conduct an in-office regulatory audit at NRC headquarters offices from February 4 - March 1, 2019, in accordance with the enclosed regulatory audit plan. If you have any questions, please contact me at 301-415-4084 or by e-mail at Emmanuel.Sayoc@nrc.gov.

Sincerely,

/RA/

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

Enclosure:

1. Regulatory Audit Plan

2. Audit Schedule

ML19015A243

• Concurred via email OFFICE PM:MRPB:DMLR LA:MRPB:DMLR PM:MRPB:DMLR BC:MRPB:DLR NAME ESayoc* YEdmonds* AWu* EOesterle*

DATE 1/14/2019 1/17/2019 1/15/2019 1/16/2019 OFFICE PM:MRPB:DMLR NAME ESayoc*

DATE 1/22/2019

Audit Plan In-Office Regulatory Audit Surry Power Station, Units. 1 and 2 Subsequent License Renewal Application February 4 - March 1, 2019 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure

Audit Plan In-Office Regulatory Audit Surry Power Station, Units. 1 and 2 Subsequent License Renewal Application

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

In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Part 54, the NRC will perform an in-office regulatory audit to gain a better understanding of (1)

Dominions methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR), and (2) Dominions aging management programs (AMPs), AMR items, Time-Limited Aging Analyses (TLAAs) and associated bases and documentation as applicable.

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

3. Regulatory Audit Scope Scoping and Screening Review The range of scoping and screening review of this regulatory audit is to review the applicants scoping and screening methodology used to identify SSCs within the scope of license renewal and subject to AMR. The review is performed to evaluate the scoping and screening process as documented in the license renewal application, implementing procedures, reports and drawings, such that the NRC staff:

• Obtains an understanding of the process used to identify the SSCs within the scope of license renewal and to identify the structures and components subject to an AMR.

• Has sufficient docketed information to allow the NRC staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied.

Enclosure 1

AMP, AMR, and TLAA Review The scope of the AMP, AMR, and TLAA review of this regulatory audit is to: (a) examine Dominions AMPs, AMR items, and TLAAs for SPS; (b) verify Dominions claims of consistency with the corresponding GALL-SLR Report AMPs, and AMR items, and (c) assess the adequacy of the TLAAs. Enhancements and exceptions will be evaluated on a case-by-case basis. The NRC staffs review of enhancements and exceptions will be documented in the safety evaluation report.

During this portion of the audit, the NRC staff will audit Program Elements 1 - 10 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions for general recommendations such as compliance with Appendix B, confirmation process, administrative controls, and operating experience) of the applicants AMPs against the elements of the associated AMP described in the GALL-SLR Report. In addition, the NRC staff will verify that the conditions at the plant are bounded by the conditions for which the GALL-SLR Report program was evaluated.

The NRC staff will also examine the applicants program bases documents and related references for AMPs, AMR items, and TLAAs, and interview applicant representatives to obtain additional clarification. Walk downs, if necessary will be performed in a subsequent audit to be performed onsite.

The NRC staff will use risk insights to inform the prioritization of its review of documentation associated with AMPs, AMR items, and TLAAs. The NRC staff will use risk insights to focus the breadth and depth of its review of plant specific operating procedures and operating experience.

However, the NRC staffs review is not limited to risk-significant systems and components because 10 CFR Part 54 is a deterministic rule and the NRC staff must conclude that there is reasonable assurance that activities will continue to be conducted in accordance with the current licensing basis and the effects of aging will be managed during the period of extended operation for all structures and components within the scope of Part 54.

The NRC staff has reviewed the list of risk-significant systems and components provided by Dominion for setting priorities for application of their scoping and screening methodology.

4. Information and Other Material Necessary for the Regulatory Audit For the in-office audit February 4 - March 1, 2019, the project team will review the license renewal application, as supplemented and revised, the AMP basis documents and other Dominion supporting documents as appropriate and requested

• The project team would like continued Dominion document review capability via the document portal. Document requests for upload to the portal shall be made as needed via the NRC safety project manager to the appropriate Dominion licensing manager.

• The NRC staff would like to hold break-out sessions, via telephone conference calls and/or official internet-based desktop sharing means, with Dominion and Surry subject matter experts to discuss various basis documents, references, condition/corrective action reports, and to interview Dominion representatives to obtain additional clarification related to the license renewal review. Break-out sessions for various technical review areas will occur at predesignated time slots during the audit, with preassigned NRC and Dominion representatives, see general schedule provided in Enclosure 2. NRC staff will

provide discussion topics and technical requests and questions to the NRC safety project manager, who will then relay the information to the Dominion licensing manager at least a week before the break-out session. All break-out sessions will be coordinated via the NRC safety project manager and the Dominion licensing manager.

5. Team Assignments Team Member Assignment Alan Huynh Reviewer - Mechanical Alexander Chereskin Reviewer - Chemical Andrew Johnson Reviewer - Mechanical Angela Buford Reviewer - Structural Angela Wu Project Manager Austin Young Reviewer - Mechanical Bart Fu Reviewer - Mechanical Brian Allik Reviewer - Mechanical Bryce Lehman Reviewer - Structural Dan Hoang Reviewer - Structural Reviewer - Vessel David Dijamco Internals Reviewer - Scoping and David Nold Screening Demetrius Murray Reviewer - Electrical Duc Nguyen Reviewer - Electrical Emmanuel Sayoc Project Manager Ganesh Cheruvenki Reviewer - Mechanical George Thomas Reviewer - Structural George Wang Reviewer - Structural James Gavula Reviewer - Mechanical Reviewer - Vessel James Medoff Internals Juan Lopez Reviewer - Structural Keith Hoffman Reviewer - Mechanical Reviewer - Vessel Mark Yoo Internals Mo Sadollah Reviewer - Electrical Reviewer - Fire Naeem Iqbal Protection Robert Davis Reviewer - Mechanical

Team Assignments (continued)

Roger Kalikian Reviewer - Mechanical Sam Cuadrado Reviewer - Structural Seung Min Reviewer - Mechanical Sheila Ray Reviewer - Electrical Shie-Jeng Peng Reviewer - Scoping and Screening Stephen Cumblidge Reviewer - Mechanical William Gardner Reviewer - General Science William Gardner Reviewer - Mechanical William Holston Reviewer - Mechanical

6. Logistics The regulatory audit will be conducted as an in-office (at NRC HQ) audit from February 4, 2019, to March 1, 2019. Entrance and exit briefings will be held at the beginning and end of the in-office audit via conference calls. Status calls during the in-office (at NRC HQ) audit will occur at least weekly, more if deemed necessary.

7. Special Requests The NRC staff requests the applicant to make available the license renewal application program basis documentation and license renewal drawings, and other documents as requested for independent searches by the regulatory audit team via the portal.

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

In-Office Audit Schedule Enclosure 2