ML25206A360

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Audit Summary in Support of License Amendment Request for Proposed Technical Specification Change to Section 3.7 Instrumentation, and Section 3.14 Circulating and Service Water System
ML25206A360
Person / Time
Site: Surry  Dominion icon.png
Issue date: 08/09/2025
From: Klos L
NRC/NRR/DORL/LPL2-1
To: Carr E
Dominion Energy
Klos L, NRR/DORL/LPL2-1
References
EPID L-2024-LLA-0118
Download: ML25206A360 (1)


Text

August 9, 2025 Eric S. Carr President - Nuclear Operations and Chief Nuclear Officer Dominion Energy Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

SURRY POWER STATION, UNIT NOS. 1 AND 2 - AUDIT

SUMMARY

IN SUPPORT OF LICENSE AMENDMENT REQUEST FOR PROPOSED TECHNICAL SPECIFICATION CHANGE TO SECTION 3.7 INSTRUMENTATION, AND SECTION 3.14 CIRCULATING AND SERVICE WATER SYSTEM (EPID L-2024-LLA-0118)

Dear Eric S. Carr:

By letter dated September 3, 2024, and as supplemented by letter dated July 21, 2025 (Agencywide Documents Access and Management System (ADAMS), Accession No. ML24248A171, and ML25202A210, respectively), Virginia Electric and Power Company, (the licensee, Dominion Energy Virginia) submitted a license amendment request (LAR) to amend the license and technical specifications (TSs) for Surry Power Station (Surry), Units 1 and 2, Subsequent Renewed Facility Operating License Nos. DPR-32 and DPR-37, respectively. The proposed amendments would revise the Surry TS to change TS Section 3.7 Instrumentation Systems, and Section 3.14, Circulating and Service Water [SW] Systems, to use of a temporary canal level probe and temporary supply line (jumper) to provide service water (SW) to the component cooling heat exchangers (CCHXs) and facilitate planned maintenance activities (i.e., cleaning, inspection, repair (as needed) of the existing SW piping.

The licensee proposes to install a carbon fiber reinforced polymer (CFRP) system on the existing concrete-encased SW supply piping to the CCHXs.

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the licensees submittal and determined that a regulatory audit would assist in the completion of the licensing review process. The NRC staff issued a regulatory audit plan on January 13, 2025 (ML24366A030).

The NRC staff conducted the regulatory audit from January 16 to July 28, 2025. The results of the regulatory audit were used by the NRC staff to finalize requests for confirmation of information.

The audit summary report is provided as an enclosure to this letter.

If you have any questions, please contact me by telephone at 301-415-5136 or by email to John.Klos@nrc.gov.

Sincerely,

/RA/

L. John Klos, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281

Enclosure:

Audit Summary cc: Listserv

Enclosure AUDIT

SUMMARY

LICENSE AMENDMENT REQUEST FOR PROPOSED TECHNICAL SPECIFICATION CHANGE TO SECTION 3.7 INSTRUMENTATION SYSTEMS, AND SECTION 3.14 CIRCULATING AND SERVICE WATER SYSTEM DOMINION ENERGY VIRGINIA SURRY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-280 AND 50-281

1.0 BACKGROUND

By letter dated September 3, 2024, and as supplemented by letter dated July 21, 2025 (Agencywide Documents Access and Management System (ADAMS), Accession No. ML24248A171, and ML25202A210, respectively), Virginia Electric and Power Company, (the licensee, Dominion Energy Virginia) submitted a license amendment request (LAR) to amend the license and technical specifications (TSs) for Surry Power Station (Surry), Units 1 and 2, Subsequent Renewed Facility Operating License No. DPR-32 and DPR-37, respectively.

The proposed amendments would revise the Surry TS to change TS Section 3.7 Instrumentation Systems, and Section 3.14, Circulating and Service Water [SW] Systems, to use a temporary canal level probe and temporary supply line (jumper) to provide service water (SW) to the component cooling heat exchangers (CCHXs) and facilitate planned maintenance activities (i.e., cleaning, inspection, repair (as needed) of the existing SW piping. The licensee proposes to install a carbon fiber reinforced polymer (CFRP) system on the existing concrete-encased SW supply piping to the CCHXs.

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the licensees submittal and determined that a regulatory audit would assist in the timely completion of the licensing review process. The NRC staff issued the regulatory audit plan on January 13, 2025 (ML24366A030), which detailed the logistics, scheduling, and audit request items in the plans attachment.

The NRC staff conducted the regulatory audit from January 16, 2025, to July 28, 2025. The results of the regulatory audit were used by the NRC staff to finalize its requests for confirmation of information identified in the audit.

The regulatory audit was performed consistent with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Revision 2, Regulatory Audits (ML24309A281).

2.0 AUDIT ACTIVITIES AND OBSERVATIONS The NRC audit team, identified in Section 3.0 of this audit summary, consisted of NRC staff and Section 3.0 of this audit summary lists the primary individuals that took part in or attended the audit.

The regulatory audit was conducted from January 16, 2025, to July 28, 2025. The NRC audit team used an internet-based portal provided by the licensee to review non-docketed information related to the application. Audit meetings via Microsoft Teams with the licensee were held on January 23, March 17, June 26, and June 30, 2025, to facilitate technical discussions of audit items that were later submitted on the docket as responses to requests for confirmation of information by the licensee.

Technical discussions were focused on the following major areas to:

Gain a better understanding of the detailed calculations, analyses, and bases underlying the LARs and confirm the NRC staffs understanding of the request.

Gain a better understanding of plant design features and implications for the LAR request.

Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.

Identify questions and requests that may become formal requests for additional information or requests for confirmation of information per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).

On July 7, 2025 (ML25182A019), the NRC issued a request for confirmation of information (RCI) needing to be submitted on the docket. By letter dated July 21, 2025 (ML25202A210), the licensee provided a supplement addressing the (RCIs).

3.0 AUDIT PARTICIPANTS The following table identifies the NRC audit team members.

Name Email Review Area (Organization)

John Klos John.Klos@nrc.gov Plant Licensing Branch LPL II-1 (LPL2-1)

Chakrapani Basavaraju Chakrapani.Basavaraju@nrc.gov Mechanical Engineering and Inservice Testing Branch John Bozga John.Bozga@nrc.gov Mechanical Engineering and Inservice Testing Branch Name Email Review Area (Organization)

Aaron Gallman Aaron.Gallman@nrc.gov Structural, Civil, and Geotechnical Engineering Branch Ali Rezai Ali.Rezai@nrc.gov Piping and Head Penetrations Branch David Nold David.Nold@nrc.gov Containment and Plant Systems Branch Raul Hernandez Raul.Hernandez@nrc.gov Containment and Plant Systems Branch 4.0 DOCUMENTS REVIEWED The licensee provided an extensive list of supporting documents (e.g., analyses, calculations, reports, drawings, and procedures) via the Surry document portal available during the audit period. Below lists the documents available on the portal that the NRC audit team reviewed during the audit.

Pipe Stress Analysis Calculation 15752.02-NPB-002-XE Revision 2; Pipe Stress Analysis of new configuration for service water temporary jumper to Component Cooling Heat Exchanger per DC-SU-11-00017; dated 4/8/2013 The Temporary Service Water Piping Response-3.2, Audit Response 3.2; dated 1/29/2025 Temporary SW Piping -Response 3.2, 2. Question 3.2 -3.3 3.4 Response; dated 1/29/2025 Isometric CCHX SW Jumper Installation, Surry Power Station - Unit 1; SU=DWG-000-2300146-1-M-300-SH-001, Rev. 0 Isometric CCHX SW Jumper Installation, Surry Power Station - Unit 1; SU=DWG-000-2300146-1-M-301-SH-001, Rev. 0 Analysis of safety Related Piping Surry Power Station - Units 1 & 2 DN-SU-EM-0023, Rev. 0 Isometric CCHX SW Jumper Installation Surry Power Station - Unit 1 2300146-1-M-300, 2/20/24, Rev. 0 Isometric CCHX SW Jumper Installation Surry Power Station - Unit 1, 2300146-1-M-300, 2/20/24, Rev. 0 Control of Heavy Loads - Response 3.5, 2/20/24, Rev. 0 Flow/Valve Operating Numbers Diagram Circulating and Service Water System Surry Power Station Unit 1 2300146-114488-FM-071A SH-002, 2/20/24, Rev. 0 Flow/Valve Operating Numbers Diagram Circulating and Service Water System Surry Power Station Unit 1 2300146-114488-FM-071A SH-004,2/20/24, Rev. 0 Temporary Service Water Piping Response 3.2, 2/20/24, Rev. 0 Pipe Support Analysis of New Configuration for Service Water Temporary Jumper to Component Cooling Heat Exchanger per DC SU-11-00017, 2/20/24, Rev 1 Piping Plan - Jumper Installation CCHX SW Inlet Pipe Repair Surry Power Station - Unit 1 2300146-1-M-100, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#1) Surry Power Station - Unit 1 2300146-1-M-201, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#2) Surry Power Station - Unit 1 2300146-1-M-202, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#3) Surry Power Station - Unit 1 2300146-1-M-203, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#4) Surry Power Station - Unit 1 2300146-1-M-204, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#5) Surry Power Station - Unit 1 2300146-1-M-205, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#6) Surry Power Station - Unit 1 2300146-1-M-206, 2/20/24, Rev. 0 30-WS-74-151 2300146-1-M-100 (HGR#7) Surry Power Station - Unit 1 2300146-1-M-207, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#8) Surry Power Station - Unit 1 2300146-1-M-208, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#9) Surry Power Station - Unit 1 2300146-1-M-209, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#10) Surry Power Station - Unit 1 2300146-1-M-210, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#11) Surry Power Station - Unit 1 2300146-1-M-211, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#12) Surry Power Station - Unit 1 2300146-1-M-212, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#13) Surry Power Station - Unit 1 2300146-1-M-213, 2/20/24, Rev. 0 30-WS-574-151 2300146-1-M-100 (HGR#14) Surry Power Station - Unit 1 2300146-1-M-214, 2/20/24, Rev. 0 SPS SW Jumper Seismic Risk Assessment, 2/20/24, Rev. 0 Missile Protection Insights - Response 3.4, 2/20/24, Rev. 0 Turbine Dismantling & Lay-Down Arrangement. Surry Power Station - Unit 1 11448-FM-61A, 2/20/24, Rev. 0 The Contingency Action Plan - Response 3.1 NPHP Audit Plan Item/Question 3.1.5 and 3.1.6 of 3.1 The Contingency Action Plan Report 241103-R-01, Revision 0, Emergency Restoration Plan for CCHX CFRP Liner Installation Report 241103-R-01, Revision A, Emergency Restoration Plan for CCHX CFRP Liner Installation Supplement to Report 241103-R-01 Shutdown Risk Management (Procedure OU-AA-200, Revision 13)

Shutdown Safety Assessment Checklist (Procedure OU-AA-201, Revision 18) 15752.02-NPB-002-XE Revision 2, Pipe Stress Analysis of New Configuration for Service Water Temporary Jumper to Component Cooling Heat Exchanger per DC SU-11-00017 ME-0281, Revision 4 Component Cooling Heat Exchanger (CCHX) Operability Curves PM-2301 Revision 0 Surry Spent Fuel Pool Loss of Cooling Heat-Up Times Calculation Number PM-1442, Revision 1 HEATUP Version 1 Spent Fuel Pool Heat-up Computer Code

ML25206A360 NRR-106 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DEX/EMIB/BC NAME JKlos KZeleznock (KEntz for)

SBailey DATE 7/23/25 7/31/2025 7/31/2025 OFFICE NRR/DEX/ESEB/BC NRR/DNRL/NPHP/BC NRR/DSS/SCPB/BC NAME ITseng MMitchell MValentin DATE 7/31/2025 7/31/2025 7/31/2025 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley JKlos DATE 8/1/2025 8/9/2025