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| {{#Wiki_filter:April 8, 2021 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 | | {{#Wiki_filter:}} |
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| ==SUBJECT:==
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| NORTH ANNA POWER STATION, UNITS 1 AND 2 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2020-SLR-0000)
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| ==Dear Mr. Stoddard:==
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| By {{letter dated|date=August 24, 2020|text=letter dated August 24, 2020}} (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML20246G703), Virginia Electric and Power Company (Dominion Energy or the applicant) submitted an application for the subsequent license renewal of Renewed Facility Operating License Nos. NPF-4 and NPF-7 for the North Anna Power Station, Units 1 and 2 (NAPS) to the U.S. Nuclear Regulatory Commission (NRC). Dominion Energy submitted the application pursuant to Title 10 of the Code of Federal Regulations Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for subsequent license renewal.
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| The NRC staff completed its aging management audit from October 13, 2020 -
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| January 8, 2021, in accordance with the in-office regulatory audit plan (ADAMS Accession No. ML20276A192). The audit report is enclosed.
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| If you have any questions, please contact me by e-mail at Lois.James@nrc.gov.
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| Sincerely, Lois M. Digitally signed by Lois M. James James Date: 2021.04.08 10:49:56 -04'00' Lois M. James, Senior Project Manager License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339
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| ==Enclosure:==
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| Audit Report cc w/encl: Listserv
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| AUDIT REPORT In-Office Regulatory Audit North Anna Power Station, Units 1 and 2, Subsequent License Renewal Application October 13, 2020 - January 8, 2021 Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure
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| U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF NEW AND RENEWED LICENSES Docket Nos: 50-338 and 50-339 License No: NPF-4 and NPF-7 Licensee: Virginia Electric and Power Company (Dominion Energy)
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| Facility: North Anna Power Station, Units 1 and 2 Location: Rockville, Maryland Dates: October 13, 2020 - January 8, 2021 Approved By: Steven D. Bloom, Chief Corrosion and Steam Generator Branch (NCSG)
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| Division of New and Renewed Licenses (DNRL)
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| Joseph Colaccino, Chief Structural, Civil, Geotech Engineering Branch B (ESEB)
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| Division of Engineering and External Hazards (DEX)
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| Lauren K. Gibson, Chief License Renewal Projects Branch (NLRP)
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| Division of New and Renewed Licenses (DNRL)
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| Hipolito J. Gonzalez, Chief Vessels and Internals Branch (NVIB)
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| Division of New and Renewed Licenses (DNRL)
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| Jeanne A. Johnston, Chief Long-Term Operations and Modernization Branch (ELTB)
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| Division of Engineering and External Hazards (DEX)
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| Scott Krepel, Chief Nuclear Systems Performance Branch (SNSB)
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| Division of Safety Systems (DSS)
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| Robert Lukes, Chief Nuclear Methods and Fuel Analysis Branch (SFNB)
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| Division of Safety Systems (DSS)
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| Matthew A. Mitchell, Chief Piping and Head Penetrations Branch (NPHP)
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| Division of New and Renewed Licenses (DNRL)
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| Shilp Vasavada, Acting Chief PRA Licensing Branch B (APLB)
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| Division of Risk Assessment
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| Brian Wittick, Chief Containment & Plant Systems Branch (SCPB)
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| Division of Safety Systems (DSS)
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| Reviewers: Name Organization Brian Allik DNRL/NCSG Michael Benson DNRL/NVIB Luis Colon Fuentes DEX/ESEB David Dijamco DNRL/NVIB Carolyn Fairbanks DNRL/NVIB Bart Fu DNRL/NPHP Jim Gavula DNRL/NCSG Allen Hiser DNRL Naeem Iqbal DRA/APLB Andrew Johnson DNRL/NCSG Roger Kalikian DNRL/NPHP Bryce Lehman DEX/ESEB Juan Lopez DEX/ESEB Greg Makar DNRL/NCSG James Medoff DNRL/NVIB Seung Min DNRL/NPHP Matthew Mitchell DEX/ELTB Duc Nguyen DEX/ELTB David Nold DSS/SCPB Peng, Shie-Jeng DSS/SCPB Andrew Prinaris DEX/ESEB Eric Reichelt DNRL/NPHP Ali Rezai DNRL/NPHP Mohammad Sadollah DEX/ELTB Christopher Sydnor DNRL/NVIB Leslie Terry DSS/SCPB George Thomas DEX/ESEB Shilp Vasavada DRA/PRA Licensing Branch C (APLC)
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| Robert Vettori DRA/APLB George Wang DEX/ESEB On Yee DNRL/NVIB Matthew Yoder DNRL/NCSG Austin Young DNRL/NPHP
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| TABLE OF CONTENT AUDIT REPORT ...................................................................................................................... TABLE OF CONTENT ............................................................................................................. ACRONYMS ............................................................................................................................ 1. Introduction ..................................................................................................................... 2. Audit Activities ................................................................................................................ SLRA AMP B2.1.1, American Society of Mechanical Engineers (ASME)
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| Section XI Inservice Inspection (ISI), Subsections IWB, IWC, and IWD ........................ SLRA AMP B2.1.2, Water Chemistry ................................................................................. SLRA AMP B2.1.3, Reactor Head Closure Stud Bolting .................................................... SLRA AMP B2.1.4, Boric Acid Corrosion ........................................................................... SLRA AMP B2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components ................................................................................................................... SLRA AMP B2.1.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) .................................................................................................................. SLRA AMP B2.1.7, Pressurized Water Reactor (PWR) Vessel Internals .......................... SLRA AMP B2.1.8, Flow-Accelerated Corrosion ............................................................... SLRA AMP B2.1.9, Bolting Integrity ................................................................................... SLRA AMP B2.1.10, Steam Generators ............................................................................ SLRA AMP B2.1.11 Open-Cycle Cooling Water System ................................................... SLRA AMP B2.1.12 Closed Treated Water Systems ......................................................... SLRA AMP B2.1.13, Inspection of Overhead Heavy Load and Light Load Handling Systems ........................................................................................................... SLRA AMP B2.1.14, Compressed Air Monitoring .............................................................. SLRA AMP B2.1.15, Fire Protection .................................................................................. SLRA AMP B2.1.16, Fire Water System ............................................................................ SLRA AMP B2.1.17, Outdoor and Large Atmospheric Metallic Storage Tanks ................. SLRA AMP B2.1.18, Fuel Oil Chemistry ............................................................................ SLRA AMP B2.1.19, Reactor Vessel Material Surveillance ............................................... SLRA AMP B2.1.20, One-Time Inspection ........................................................................ SLRA AMP B2.1.21, Selective Leaching ............................................................................ SLRA AMP B2.1.22, ASME Code Class 1 Small-Bore Piping ........................................... SLRA AMP B2.1.23, External Surfaces Monitoring of Mechanical Components ............... SLRA AMP B2.1.24, Flux Thimble Tube Inspection Program ............................................
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| SLRA AMP B2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components ............................................................................................... SLRA AMP B2.1.26, Lubricating Oil Analysis .................................................................... SLRA AMP B2.1.27, Buried and Underground Piping and Tanks ...................................... SLRA AMP B2.1.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks ................................................................... SLRA AMP B2.1.29, ASME Section XI, Subsection IWE ................................................... SLRA AMP B2.1.30, ASME Section XI, Subsection IWL ................................................... SLRA AMP B2.1.31, ASME Section XI, Subsection IWF ................................................... SLRA AMP B2.1.32, 10 CFR Part 50, Appendix J ............................................................. SLRA AMP B2.1.33 Masonry Walls ................................................................................... SLRA AMP B2.1.34, Structures Monitoring ........................................................................ SLRA AMP B2.1.35 Inspection of Water-Control Structures Associated With Nuclear Power Plants ..................................................................................................... SLRA AMP B2.1.36, Protective Coating Monitoring and Maintenance .............................. SLRA AMP B2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements...................... SLRA AMP B2.1.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits .............................................................................................. SLRA AMP B2.1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ......... SLRA AMP B2.1.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ........ SLRA AMP B2.1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ......... SLRA AMP B2.1.42, Metal Enclosed Bus .......................................................................... SLRA AMP B2.1.43, Fuse Holders .................................................................................... SLRA AMP B2.1.44, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements .................................................................... SLRA AMP B2.1.45, High-Voltage Insulators .................................................................... SLRA AMP B3.1 Fatigue Monitoring Program ................................................................... SLRA AMP B3.2, Neutron Fluence Monitoring Program .................................................... SLRA AMP B3.3, Environmental Qualification (EQ) of Electric Equipment ....................... SLRA TLAA Section 4.1.1, Identification of Time-Limited Aging Analyses and TLAA Section 4.1.4, Identification of Exemptions ........................................................ SLRA TLAA Section 4.2.2, Upper-Shelf Energy ................................................................ SLRA TLAA Section 4.2.3, Pressurized Thermal Shock .................................................... SLRA TLAA Section 4.2.4, Adjusted Reference Temperature ......................................... - 101 -
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| SLRA TLAA Section 4.2.5, Pressure-Temperature Limits ............................................... - 103 -
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| SLRA TLAA Section 4.2.6, Low Temperature Overpressure Protection .......................... - 104 -
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| SLRA TLAA Section 4.3, Metal Fatigue ........................................................................... - 105 -
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| SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment .................. - 108 -
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| SLRA TLAA Section 4.6 Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis and SLRA Section 3.5.2.2.1.5 Cumulative Fatigue Damage .......................................................................................................... - 110 -
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| SLRA TLAA Section 4.7.1, Crane Load Cycle Limits ....................................................... - 111 -
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| SLRA TLAA Section 4.7.2, Reactor Coolant Pump Flywheel Fatigue Crack Growth....... - 113 -
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| SLRA TLAA Section 4.7.3, Leak-Before-Break ................................................................ - 114 -
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| SLRA TLAA Section 4.7.4, Spent Fuel Pool Liner Fatigue Analysis ................................ - 115 -
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| SLRA TLAA Section 4.7.7, Cracking Associated with Weld Deposited Cladding ............ - 116 -
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| SLRA TLAA Section 4.7.8, Steam Generator Tube Wear Evaluation .............................. - 117 -
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| AMR Item Not Associated with an AMP ........................................................................... - 118 -
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| : 3. Supplement to the SLRA .............................................................................................. - 127 -
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| : 4. Applicant Personnel Contacted During Audit ............................................................... - 127 -
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| : 5. Exit Meeting .................................................................................................................. - 127 -
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| Audit Questions Provided to the Virginia Electric and Power Company During the In-Office Regulatory Audit ................................................................................................... Enclosure Topics Supplemented by Virginia Electric and Power Company As a Result of Regulatory Audit Breakouts .............................................................................................................. Enclosure ACRONYMS AAC all aluminum conductor AC alternating current ACSR aluminum conductor steel-reinforced cable ADAMS Agencywide Documents Access and Management System AFW auxiliary feedwater AFWPH auxiliary feedwater pump house ALARA as low as reasonably achievable AMA aging management analysis AMP aging management program AMR aging management review ANSI American National Standards Institute ABPA acceptable bolting pattern analysis ART adjusted reference temperature ASME American Society of Mechanical Engineers ASTM American Society of Testing Materials BA boric acid BACC boric acid corrosion control BFB baffle-former bolt BMI bottom mounted instrumentation CASS Cast Austenitic Stainless Steel CAT chemical addition tank CBS Concrete Biological Shield CC component cooling CCCW closed-cycle cooling water CFR Code of Federal Regulations CLB current licensing basis CO2 carbon dioxide CR condition report CRDM Control Rod Drive Mechanism CRGT Control Rod Guide Tube CUF cumulative usage factor CUFen environmentally-adjusted cumulative usage factor DC design change DCP design change package DM dissimilar metal DO dissolved oxygen Dominion Energy Virginia Electric and Power Company dpm drops per minute
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| EAF Environmentally-Assisted Fatigue ECST emergency condensate storage tanks EDG emergency diesel generator EFPY effective full power years EPRI Electric Power Research Institute FAC Flow-Accelerated Corrosion FB fuel building FE Further Evaluation FMP fatigue monitoring program FOSAR Foreign Object Search and Retrieval FSWOL full structural weld overlay ft-lb foot-pound FWPH feedwater pump house GALL-SLR NUREG-2191, Rev. 0, Generic Aging Lessons Learned for Subsequent License Renewal GL Generic Letter HELB high energy line break HX heat exchanger I&E inspection and evaluation IA instrument air ILRT integrated leak rate test ISG Interim Staff Guidance ISI inservice inspection ksi kilopounds per square inch LAR license amendment request LBB leak-before-break LER license event report LR license renewal LTOP low temperature overpressure protection MIC microbiologically influenced corrosion MOV motor operated valve MPM mechanical preventative maintenance MRP materials reliability program mV milliVolt MWt megawatt-thermal NACE National Association of Corrosion Engineers
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| NANN North Anna Nuclear Station NAPS North Anna Power Station NDE nondestructive examination NEI Nuclear Energy Institute NOD notice of deficiency NRC U.S. Nuclear Regulatory Commission NSS nuclear steam system NSSS nuclear steam supply system NST neutron shield tank OpE operating experience P-T pressure-temperature PTS Pressurized Thermal Shock PWR pressurized water reactor PWROG Pressurized Water Reactor Owners Group PWSCC primary water stress corrosion cracking QC quality control RAI request for additional information RCI request for confirmation of information RCL reactor coolant loop RCP Reactor Coolant Pump RCS reactor cooling system RFO refueling outage RIS regulatory information summary RPV reactor pressure vessel RSHX recirculation spray heat exchangers RSST reserve station service transformer RTNDT reference temperature nil ductility RTPTS reference temperature for pressurized thermal shock RV reactor vessel RVI reactor vessel internal RWST refueling water storage tank SCC stress corrosion cracking SE safety evaluation SER safety evaluation report SG steam generator SLR Subsequent License Renewal SLRA subsequent license renewal application SOV solenoid-operated valve SPS Surry Power Station
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| SRP-SLR NUREG-2192, Rev. 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants SW service water SWGR switchgear SWOL structural weld overlay TLAA Time-Limited Aging Analyses UFSAR Updated Final Safety Analysis Report USAS United States of America Standards USE upper-shelf energy UT ultrasonic testing VT Visual examination WO work order WOG Westinghouse Owners Group WOL weld overlay
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| Report for the In-Office Regulatory Audit North Anna Power Station, Units 1 and 2 Subsequent License Renewal Application
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| : 1. Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an in-office audit of Virginia Electric and Power Company (Dominion Energy, applicant) (1) plant-specific operating experience (OpE), (2) 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) (Scoping and Screening Portion), and (3) aging management programs (AMPs),
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| AMR items, Time-Limited Aging Analyses (TLAA) and associated bases and documentation as applicable (AMP and TLAA Portion) for the subsequent license renewal of Renewed Facility Operating License Nos. NPR-4 and NPR-7 for North Anna Power Station, Units 1 and 2 (NAPS).
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| Due to the travel restrictions associated with the coronavirus, no on-site audit activities of OpE or visual observations of areas, equipment conditions, or configurations were conducted. Upon the staffs request, Dominion Energy showed the staff pictures of plant conditions via video conferencing. These pictures were not transmitted, were not provided to the staff, and were not placed on the docket.
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| The purpose of the plant-specific OpE Portion of the audit is to identify examples of age-related degradation, as documented in the applicants corrective action program database. Using the same set of key words used by NRC staff in previous OpE database searches, Dominion Energy searched their OpE database. The results of the initial search were culled to eliminate duplicative and non-relevant results, and the results were provided in the basis documents for the associated AMPs and TLAAs for NRC staff review. Additional word searches were performed by Dominion Energy upon NRC staffs request, and the results were provided to the NRC staff for review.
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| The purpose of the Scoping and Screening Portion of the audit is to evaluate the scoping and screening process as documented in the license renewal application, implementing procedures, reports, and drawings, such that the NRC staff:
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| 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.
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| Has sufficient docketed information to allow the staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied.
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| The purpose of the AMP and TLAA Portion of the audit is to:
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| Examine Dominion Energys AMPs, AMR items, and TLAAs for Surry Power Station (SPS);
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| Verify Dominion Energys claims of consistency with the corresponding NUREG-2191, Rev. 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR)
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| Report, issued in July 2017, AMPs, and AMR items; and Assess the adequacy of the TLAAs.
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| 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 (SER).
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| The regulatory bases for the audit was Title 10 of the Code of Federal Regulations, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, (10 CFR Part 54).
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| The staff also considered the guidance contained 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. The SRP-SLR allows an applicant to reference in its license renewal application the AMPs described in GALL-SLR Report. By referencing the GALL-SLR Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL-SLR Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL-SLR Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL-SLR Report program. The applicant should document this determination in an auditable form and maintain the documentation on-site.
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| : 2. Audit Activities A regulatory audit is a planned, license-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain greater understanding of an application, to verify information, and, if applicable, to identify information that will require docketing to support the staffs conclusions that form the basis of the licensing or regulatory decision.
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| Licensing conclusions or staff findings are not made in the audit reports since licensing and regulatory decisions cannot be made solely based on an audit. Therefore, items identified but not resolved within the scope of the audit will be followed using other NRC processes, such as requests for additional information (RAIs), requests for confirmation of information (RCIs), and public meetings. Licensing conclusions, staff findings, and resolution of audit items will be documented in the staffs SER.
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| The following sections discuss the subsequent license renewal application (SLRA) areas reviewed by the staff.
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| SLRA AMP B2.1.1, American Society of Mechanical Engineers (ASME) Section XI Inservice Inspection (ISI), Subsections IWB, IWC, and IWD Summary of Information in the Application. The SLRA states that AMP B2.1.1, ASME Section XI ISI, Subsections IWB, IWC, and IWD is an existing program that will be consistent with the program elements in GALL-SLR Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities.
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| During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the ASME Section XI ISI, Subsections IWB, IWC, and IWD program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date PNNL-21546 Evaluation of Manual Ultrasonic Examinations 06/2012 Applied to Detect Flaws in Primary System Dissimilar Metal Welds at North Anna Power Station ETE-SLRA-2020- North Anna Subsequent License Renewal Project- 08/2020 2304 Aging Management Evaluation Report- ISI Program Revision 0 PIR 1079417 Fleet Inservice Inspection Program Formal Self- 01/24/2018 Assessment Condition Report Pre-Overlay Manual UT [Ultrasonic testing] Exam 03/25/2012 (CR) 467716 Failed to Identify Longitudinal Subsurface Flaws PA 7503466 AMP Effectiveness Review - Inservice Inspection 04/2019 Program CR 472354 Reactor Vessel Interior (B-N-1) Examination Not 04/25/2012 Performed for ISI Period CR 1038564 NOD Audit Finding16-04-01NS: Admin Control Not 05/26/2016 Effective for Changes for License Renewal Program CR 348719 Components not in Current ISI Inspection Plan 09/17/2019 CR 535562 EPRI [Electric Power Research Institute] Notification 12/19/2013 of Code Noncompliance Issues PIR 1112472 NANN [North Anna Nuclear Station] and MPS to 12/13/2018 Perform an Effectiveness Review of All Initial License Renewal AMAs [Aging Management Analysis]/AMPs ER-AA-NDE-142 Procedure for the Indoctrination of Supplemental Revision 2 NDE [nondestructive examination] Personnel During the audit, the staff identified enhancements associated with the scope of program and detection of aging effects program elements.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP provided in the Updated Final Safety Analysis Report (UFSAR) supplement. The staff verified that this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.2, Water Chemistry Summary of Information in the Application. The SLRA states that AMP B2.1.2, Water Chemistry is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M2, Water Chemistry, as modified by Interim Staff Guidance (ISG) SLR-ISG-Mechanical-2020-XX, Updated Aging Management Criteria for Mechanical Portions of the
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| Subsequent Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. The referenced ISG had not been issued as final at the time of the audit. The staff will document its review of the consistency of the AMP with the final ISG in its SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Water Chemistry program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 115962 Unit 2 RCS [reactor cooling system] Hydrogen Out of 10/26/2008 Specification High CR 516620 Steam Generator Sulfate Elevated During Forced Outage 05/24/2013 CR 575622 U1 SGA [steam generator A] Sodium and Fluoride Values 03/31/2015 were Elevated During Unit Startup CR 578822 Higher than Expected Increase in Sodium in U2 SG 05/05/2015
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| [steam generator] After Circ Pump Start CR 580294 Elevated Unit 1 RCS Chloride 05/21/2015 CR 1094641 1-CH-I-2 (U1 Cation Bed) PG Flush Does Not Meet 04/13/2018 Chemistry Specifications CR 1113347 Unit 1 Steam Generator Sodium Concentration Exceeded 01/04/2019 Action Level 1 Limits, CM-AA-DDC-201 Design Change Update (Condensate Polishing Valve 02/20/2019 Replacement, Unit 1)
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| DNES-AA-GN-1002 Operational Acceptance Checklist (Cut and Cap U1 08/2019 /
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| Sample Lines) 09/2019 DC NA-19-00040 Condensate Polishing Valve Replacement, Unit 2 10/2019 Work Order WO 59203296740 Cut and Cap U2 Sample Lines 09/2019 /
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| (WO) 59203296740 10/2019 CY-AA-100 Conduct of Chemistry Revision 13 CY-AP-PRI-100 Primary System Chemistry Revision 10, Revision 11 CY-AP-SEC-200 Secondary System Chemistry Revision 8 CH-93.131 Chemistry Controls: Primary-Side Unit Startup Revision 15 CH-99.500 Primary Chemistry Specifications and Action Levels Revision 20 CH-99.502 Strategic Primary Water Chemistry Plan Revision 6 CH-99.600 Secondary Chemistry Specifications and Action Levels Revision 19 CH-99.602 Secondary Chemistry Strategic Water Chemistry Plan Revision 1
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| Document Title Revision / Date EE-AA-SGP-101 Steam Generator Program Revision 0 EPRI Report No. Pressurized Water Reactor Secondary Water Chemistry Revision 7 3002000505 Guidelines 04/24/2014 EPRI Report No. Pressurized Water Reactor Secondary Water Chemistry Revision 8 3002010645 Guidelines N/A Technical Requirements Manual for North Anna Units 1 & Revision 28 2, Section 3.4.1 N/A Chemistry trend data primary plots 2015-2020 N/A Chemistry trend date secondary plots 2015-2020 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP Water Chemistry program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.3, Reactor Head Closure Stud Bolting Summary of Information in the Application. The SLRA states that AMP B2.1.3, Reactor Head Closure Stud Bolting, is an existing program with an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M3, Reactor Head Closure Stud Bolting. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the exception associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Reactor Head Closure Stud Bolting program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CA 467019 1-CR-R-1 reactor head stud #32 was found to have 03/20/2012 surface pitting in the non-threaded area CA 230134 Inspection of reactor head flange and stud hole #32 for 03/22/2012 any boric acid degradation CR 467023 1-RC-R-1 reactor head stud #34 was found to have a 03/20/2012 deformation in the lower portion of stud at the non-threaded area
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| Document Title Revision / Date CR 467207 Performance of NDE on reactor head stud #34 03/21/2012 CR 467247 Indications on reactor vessel studs. 03/22/2012 CR 467572 Reactor vessel studs failed QC [quality control] inspection 03/23/2012 due to pitting and corrosion CR 467486 QI [Quality inspector ] inspection on # 46, 55, 58 studs 03/23/2012 found slight indications ETE-SLR-2020- Engineering Technical Evaluation - AMP Evaluation Revision 0, 2306 Report for Reactor Head Closure Stud Bolting 07/27/2020 NRC Regulatory Materials and Inspections for Reactor Vessel Closure Revision 1, Guide 1.65 Studs 04/2020 NRC Safety North Anna Power Station, Units 1 and 2 - Proposed 12/06/2017 Evaluation Letter Inservice Inspection Alternatives N1-I4-NDE-009 and N2-I4-NDE-004 (CAC Nos. MF9298 and MF9299; EPIDS L-2016-LLR-0018) (ADAMS Accession No. ML17332A663)
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| EPRI Report Nondestructive Evaluation: Reactor Pressure Vessel 03/2016 3002007626 Threads in Flange Examination Requirements Regulatory Qualification Requirements for Bolts and Stud 04/23/2019 Information Nondestructive Examination Summary (RIS) 2015-01 During the audit, the staff verified that for the program elements that Dominion Energy declared were consistent, the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of SLRA AMP are consistent with the corresponding program elements in the GALL-SLR Report AMP.
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| The staff also verified Dominion Energys claim that aspects of the preventive actions and corrective actions program elements not associated with the exception identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit, the staff made the following observations:
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| The staff reviewed the program basis document and noted that the document provides supporting evidence that the ISI performed as part of this AMP has been effective in both detecting stress corrosion cracking (SCC) and managing aging effects of the reactor head closure stud bolting. As an example, a visual examination revealed a minor deformation in the lower portion of the non-threaded area of a stud, a magnetic particle examination identified minor surface indications on the lower shank of the stud, and a volumetric examination showed no evidence of internal indications. Dominion Energys evaluations determined that these minor indications identified by the ISI would not affect the studs strength or its ability to provide clamping force on the reactor head.
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| The staff noted that not all reactor head closure studs at NAPS have supporting documentations to validate that the measured yield strength does not exceed
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| 150 kilopounds per square inch (ksi) for newly installed studs or the measured ultimate tensile strength does not exceed 170 ksi for existing studs. This could present a potential for the SCC degradation of the studs. To manage SCC, the ultrasonic examination has been performed on the studs in accordance with ASME Code, Section XI, Table IWB-2500-1, Examination Category B-G-1 as part of this AMP. The staffs review of NAPS OpE revealed no evidence of SCC degradation of reactor head closure studs.
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| In addition, Dominion Energy will continue to perform the ASME Code, Section XI, Table IWB-2500-1, Examination Category B-G-1 required examinations on the reactor head closure studs and associated components during the period of extended operation as part of this AMP.
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| The staff also audited the description of the SLRA Reactor Head Closure Stud Bolting program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
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| SLRA AMP B2.1.4, Boric Acid Corrosion Summary of Information in the Application. The SLRA states that AMP B2.1.4, Boric Acid Corrosion, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M10, Boric Acid Corrosion. The SLRA notes that this program is implemented as a Dominion Energy Fleet program and that the program requirements and implementation procedures were previously reviewed by the NRC staff and determined to be acceptable.
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| Audit Activities.
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| During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Boric Acid Corrosion program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020-2307 Aging Management Program Evaluation Report - Boric Revision 0 Acid Corrosion ER-AP-BAC-10 Boric Acid Corrosion Control [BACC] Program Revision 13 ER-AP-BAC-101 Boric Acid Corrosion Control Program Inspections Revision 13 ER-AP-BAC-102 Boric Acid Corrosion Control Program Evaluations Revision 14 0-PT-119 Boric Acid Corrosion Control Walkdown Revision 6 1-PT-48 Visual Inspection of Reactor Coolant Pressure Boundary Revision 26 Components 1-PT-46.21 RCS Pressure Boundary Components Affected by Boric Revision 32 Acid Accumulation CR 1065118 01-CH-FCV-1113A does not have a current formal BACC 04/12/2017
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| [boric acid corrosion control] evaluation on file CR 1077865 Body to bonnet leak found at 2-RC-MOV-2590 09/13/2017
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| Document Title Revision / Date CR 1080698 Boric Acid leak on 2-CH-TCV-2143 10/12/2017 CR 1089222 Excessive BA [boric acid] leakage on 2-CH-TCV-2143 02/02/2018 CR 1090645 Leakage has returned on 2-CH-TCV-2143 02/23/2018 CR 108533 Inactive BA leak on 1-RP-ICV-3015 12/10/2017 CR 1086967 BACC leak has returned on 1-RP-ICV-3015 01/02/2018 CR 1088412 Dried BA identified at packing area 1-RP-ICV-3015 01/22/2018 CR 1088566 Active BA leak 1-RP-ICV-3015 01/24/2018 WO 59203303611 NAPS BACC Leaks List 07/13/2020 WO 59203294336 NAPS BACC Leaks List 01/14/2020 During the audit, the staff verified Dominion Energys statement that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also reviewed the summary description of the program provided in SLRA Appendix A, UFSAR Supplement, Section A1.4, Boric Acid Corrosion. The staff verified this description is consistent with the corresponding program description in GALL-SLR Report Table XI-01.
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| SLRA AMP B2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Summary of Information in the Application. The SLRA states that AMP B2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 467716 Pre-Overlay Manual UT Exam Failed to Identify 03/25/2012 Longitudinal Subsurface Flaws CR 467649 Through-wall cracks were observed on the Unit 1 SG Hot 03/24/2012 Leg Weld WO 59102768136 Ultrasonic examination of A SG cold leg DM [dissimilar 03/13/2015 N1R24 metal] weld WO 59102768136 Ultrasonic examination of A SG hot leg WOL [weld 03/13/2015 N1R24 overlay]
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| WO 50102442827 Vessel head volumetric inspection 03/21/2012 1-PT-48.7 N1R22 WO 59077176201 Vessel head volumetric inspection 02/06/2006 2-PT-48.7 N2R18 WO 59077176101 Vessel head bare metal visual inspection 02/06/2006 2-PT-48.6 N2R18 WO 59102944290 Bare metal inspection of vessel BMI [bottom mounted Revision 8, 2-PT-48.4 N2R26 instrumentation] nozzles 03/03/2019 WO 59102643574 Bare metal inspection of vessel BMI nozzles Revision 6, 1-PT-48.4 N1R25 09/12/2016 ETE-SLR-2020- Engineering Technical Evaluation - AMP Evaluation Revision 1, 2308 Report for Cracking of Nickel-Alloy Components and Loss 08/2020 of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components CR 520730 NDE has issued N & GP requirements per [Nuclear 07/16/2013 Energy Institute] NEI 03-08 (EPRI Report 3002000204)
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| CR 520729 NDE has issued N & GP requirements per NEI 03-08 07/16/2013 (EPRI Report 3002000091)
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| CR 556049 Evaluation of INPO Event Report (IER) 14-40 for 08/13/2014 Ultrasonic Reliability Issues EPRI Report Nondestructive Evaluation: Guideline for Conducting Revision 1, 3002000091 Ultrasonic Examinations of Dissimilar Metal Welds 05/2013 ER-AA-MAT-11 Alloy 600 Management Plan Revision 16 RIS 2018-06 Clarification of the Requirements for Reactor Pressure 12/10/2018 Vessel Upper Head Bare Metal Visual Examinations RIS 2015-10 Applicability of ASME Code Case N-770-1 as Conditioned 07/16/2015 in 10 CFR 50.55a, Codes and Standards, to Branch Connection Butt Welds EPRI Report Materials Reliability Program: Guideline for Nondestructive Revision 1, 3002017288 Examination of Reactor Vessel Upper Head Penetrations, 12/2019 Revision 1 (MRP-384)
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| ER-AA-NDE-147 Procedure for the implementation of materials reliability Revision 1, program (MRP), Guideline for NDE of reactor vessel upper 07/30/2020 head penetrations (MRP-384)
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| During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit, the staff made the following observations:
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| From review of the program basis document, the staff verified that this document provides supporting evidence that the augmented ISIs performed as part of this AMP have been effective in detecting the primary water stress corrosion cracking (PWSCC) in the nickel-alloy welds and components as well as identifying the presence of boric acid residues. Although one example does exist in the 2012 NAPS OpE that discussed a failure of the ultrasonic testing (UT) to identify PWSCC in a steam generator nozzle to safe end dissimilar metal (DM) butt weld, corrective measures had been taken by Dominion Energy and industry as a whole to address the causes and improve the ultrasonic procedures and practices for the DM welds. The staffs review of NAPSs OpE revealed no other PWSCC degradations or boric acid residues on the nickel-alloy welds and components.
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| The staffs review of NAPS OpE revealed that Dominion Energy revised its fleet nondestructive examination (NDE) procedures and practices to include the latest industry guidance and best practices developed for the ultrasonic examinations of DM welds based on lessons learned from the 2012 NAPS OpE in an effort to improve the overall UT reliability. This latest industry guidance for the DM welds examinations are to be implemented under Nuclear Energy Institute (NEI) 03-08 implementation criteria.
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| The staff noted that Dominion Energy has a living Alloy 600 management plan program for its entire fleet that is regularly updated to provide long-term strategies for management of Alloy 600/82/182 susceptibility to PWSCC degradation.
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| The staff interviewed Dominion Energy to clarify whether the guidance in Electric Power Research Institute (EPRI) Report 3002017288, Materials Reliability Program: Guideline for Nondestructive Examination of Reactor Vessel Upper Head Penetrations, Revision 1 (MRP-384), as required under NEI 03-08 implementation criteria, has been implemented at NAPS. Dominion Energy provided documentation to confirm its implementation at NAPS.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.The staff also audited the description of the SLRA Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
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| SLRA AMP B2.1.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)
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| Summary of Information in the Application. The SLRA states that AMP B2.1.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS), is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS). To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities.
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| During its audit, the staff interviewed the applicants staff,and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the thermal Aging Embrittlement of CASS program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date WO 59203136641 WO to perform ISI and Augmented ISI Inspection during Unit 2 Revision 0, Refuel Outages 2019 WO 59102983133 WO to perform N1R25 NDE for ISI and Augmented ISI Program Revision 0, 2016 WO 59102695275 WO to perform N2R23 NDE for ISI and Augmented ISI program Revision 0, 2014 WO 59102422876 WO to perform N1R22 NDE for ISI and Augmented ISI program Revision 0, 2012 ETE-SLR-2020-2309 Engineering Technical Evaluation - AMP Evaluation Revision 1, Report for Thermal Aging Embrittlement of Cast 07/2020 Austenitic Stainless Steel (CASS)
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| WCAP-18506 Flaw Tolerance Evaluation for Susceptible Reactor Revision 0, Coolant Loop Cast Austenitic Stainless Steel Elbow 01/2020 Components for North Anna Units 1 and 2 LTR-SDA-II-19-13 North Anna Units 1 and 2 SLR Control Rod Drive Revision 0, Mechanism Thermal Aging Embrittlement Evaluation 03/15/2019 NRC Grimess Letter License Renewal Issue No. 98-0030, Thermal Aging 05/19/2000 Embrittlement of Cast Austenitic Stainless Steel Components PWROG-17033-NP Update for Subsequent License Renewal: WCAP-13045, Revision 1,
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| 'Compliance to ASME Code Case N-481 of the Primary 06/2018 Loop Pump Casings of Westinghouse Type Nuclear Steam Supply Systems' WCAP-15555 A Demonstration of Applicability of ASME Code 08/2000 Case N-481 to the Primary Loop Pump Casings of the North Anna and Surry Units 1 and 2 for the License Renewal Program During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit, the staff made the following observations:
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| From review of the program basis document, the staff verified that this document provides supporting evidence that the ASME Code, Section XI periodic inspections performed as part of this AMP using a qualified visual, surface, or volumetric
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| examination technique have been effective in monitoring the primary coolant CASS piping components for cracking due to thermal aging embrittlement. The staffs review of OpE revealed that no cracking due to the thermal aging effect was detected in the thermally aged CASS piping components of NAPS by the examinations performed. In addition, the flaw tolerance evaluation performed for the thermally-embrittled CASS material in the hot leg, crossover leg, and cold leg piping demonstrated that the thermally-embrittled CASS material has adequate toughness.
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| The staff noted that NAPS primary loop coolant system has elbows made of statically cast A-351 Grade CF8M material and straight piping made of centrifugally cast A-351 Grade CF8A material that are thermally aged during service. Dominion used NUREG-2191 screening criteria based on the molybdenum content, casting method, and ferrite content to assess the susceptibility of cast elbow and pipe components at NAPS to thermal aging embrittlement. Ferrite content was calculated from chemical composition using Hulls equivalent factor described in NUREG/CR-4513, Revision 1 or 2, Estimation of Fracture Toughness of Cast Stainless Steels During Thermal Aging in LWR Systems. It is noted that description of Hulls equivalent factor correlation is similar in both revisions of NUREG/CR-4513. Dominion Energys assessment revealed that the CASS elbows are potentially susceptible to thermal aging.
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| The staff noted that Dominion Energy performed the flaw tolerance evaluation of the susceptible CASS in accordance with ASME Code, Section XI, IWB-3640 and Appendix C with the guidance provided in NUREG-2191. In addition, Dominion utilized the flaw tolerance evaluation procedures and acceptance criteria contained in ASME Code Case N-838, Flaw Tolerance Evaluation of Cast Austenitic Stainless Steel Piping, Section XI, and Appendix C of the 2019 Edition of ASME Code, Section XI, as applicable based on delta ferrite content.
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| The staff also audited the description of the SLRA Thermal Aging Embrittlement of CASS provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.7, Pressurized Water Reactor (PWR) Vessel Internals Summary of Information in the Application. The SLRA states that AMP B2.1.7, PWR Vessel Internals, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M16A, PWR Vessel Internals. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements for the SLRA AMP and other issues identified below in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the PWR Vessel Internals program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020-2310 North Anna Subsequent License Renewal Project - Revision 2 Aging Management Program Evaluation Report - PWR Vessel Internals 1-GEP-22.1 General Engineering Procedure, Reactor Vessel Baffle- Revision 1 Former Bolt and Baffle-Edge Bolt Examinations (Current Version for Implementation and Draft Markup for SLR) 1-GEP-22.2 General Engineering Procedure, Control Rod Guide Revision 1 Tube (CRGT) Guide Card and Flange Weld Inspections (Current Version for Implementation and Draft Markup for SLR) 1-GEP-22.3 General Engineering Procedure, Reactor Vessel Hold Revision 1 Down Spring Inspection and Measurement 1-GEP-22.4 General Engineering Procedure, Reactor Vessel Core Revision 1 Barrel Assembly, Upper Core Barrel Flange Weld Examination and Upper Core Barrel Girth Weld Examination (Current Version for Implementation and Draft Markup for SLR)
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| ER-AA-RII-101 Fleet Reactor Internals Inspection Program Revision 7 ER-NA-AUG-101 North Anna Augmented Inspection Program (Current Revision 10 Version for Implementation and Draft Markup for SLR)
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| CR 375343 Slight Impact Damage on Core Barrel Keyways (Unit 2) 04/10/2010 CR 1048448 Three Baffle-Former Bolts Have Confirmed Flaw 10/08/2016 Indications (Unit 1)
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| CR 1048581 Tie-Rod Hole in Unit 1 CRGT J-7, Guide Card 7 is Oval 10/01/2016 and Not Circular CR1093168 Wear Found on RPV [reactor pressure vessel] Radial 04/08/2018 Support Clevis Inserts (Unit 1)
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| CR1093168 Vendor Photos of Wear Found on RPV Radial Support 03/23/2018 Clevis Inserts (Unit 1)
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| CR1049685 Evaluation of CRGT Guide Card Wear (Unit 1) 03/31/2017 CR1118597 Results of Unit 2 Baffle-to-Former Bolt Examination 03/24/2019 Numerous CRs North Anna Operating Experience Detail Report, PWR 2009 - 2019 (Summaries) Vessel Internals Numerous CRs North Anna Operating Experience List Report, PWR 2009 - 2019 (Listing) Vessel Internals ETE-NA-2016-0078 North Anna Unit 1 MRP-227-A Reactor Vessel Internals Revision 0 Inspections Engineering Evaluation (Phase 1 Inspections, Fall 2016)
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| ETE-NA-2018-0008 North Anna Unit 1 MRP-227-A Reactor Vessel Internals Revision 0 Inspections Engineering Evaluation - Phase 2: Reactor Vessel Core Barrel Weld Exams and Balance MRP-227-A Examinations (Spring 2018)
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| ETE-NA-2019-0003 North Anna Unit 2 MRP-227-A Reactor Vessel Internals Revision 0 Inspections Engineering Evaluation (Phase 1 Inspections, Spring 2019)
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| Document Title Revision / Date ETE-NA-2020-0026 North Anna Unit 2 MRP-227-A Reactor Vessel Internals Revision 0 Inspections Engineering Evaluation - Phase 2: Reactor Vessel Core Barrel Weld Exams and Balance MRP-227-A Examinations (Fall 2020)
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| No Document Component Report PWR Vessel Internals (Aging Effects 09/28/2020 Number Screening)
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| EPRI Materials Transmittal of NEI-08-08 Needed Interim Guidance 01/17/2018 Reliability Program Regarding MRP-227-A and MRP-227, Revision 1 Baffle-(MRP) MRP 2018- Former Bolt Expansion Inspection Requirements for 002 PWR Plants EPRI MRP 2018-007 Transmittal of NEI-03-08 Needed Interim Guidance to 03/07/2018 Address Accelerated Guide Card Wear Operating Experience (OpE) Discussed in NSAL-17-1 EPRI MRP 2018-010 Notification of Recent PWR CRDM [Control Rod Drive 04/20/2018 Mechanism] Thermal Sleeve Flange Wear and Control Rod Motion Stoppage Operating Experience and Recommended Plant Actions Westinghouse Tech Fuel Alignment Pin Malcomized Surface Degradation 08/15/2016 Bulletin TB-16-4 During the audit, the staff verified that for the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the detection of aging effects, monitoring and trending, and acceptance criteria program elements, sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing an RAI in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| The staff reviewed ETE-SLR-2020-2310, Revision 2 and noted that the applicants SLRA AMP is based on the 60-year inspection and evaluation (I&E) guidelines for PWR vessel internal components in EPRI Materials Reliability Program (MRP) Topical Report MRP-227, Revision 1-A, Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, December 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19339G364), as supplemented by a gap analysis. The gap analysis identifies enhancements to the program that are needed to address an 80-year operating period. The staff identified that the gap analysis incorporates the industrys subsequent license renewal (SLR) interim guidance for PWR vessel internals AMPs in EPRI MRP 2018-022, Transmittal of MRP-191 Screening, Ranking, and Categorization Results and Interim Guidance in Support of Subsequent License at U.S. PWR Plants, August 31, 2018 (ADAMS Accession No. ML19081A061).
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| The staff reviewed ETE-SLR-2020-2310, Revision 2 and verified that the SLRA AMP includes I&E guidelines for the following PWR vessel internal components based on EPRI MRP 2018-022:
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| o Westinghouse Primary Components Clevis Insert Bolts Clevis Insert Dowels Control Rod Drive Mechanism (CRDM) Thermal Sleeves Radial Support Keys, Stellite Wear Surfaces Clevis Inserts, Stellite Wear Surfaces o Westinghouse Existing Programs Components Malcomized Fuel Alignment Pins (Upper Internals Assembly)
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| Malcomized Fuel Alignment Pins (Lower Internals Assembly)
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| The staff reviewed ETE-SLR-2020-2310, Revision 2 and noted that, in addition to I&E guidelines based on EPRI MRP 2018-022, the SLRA AMP also includes component-specific industry guidelines addressing relevant emergent industry experience for the following PWR vessel internal components:
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| o CRDM thermal sleeves are inspected and evaluated in accordance with NEI 03-08 Needed Interim Guidance for PWR CRDM Thermal Sleeve Wear provided in EPRI MRP 2018-027, August 31, 2018 (ADAMS Accession No. ML18253A064) o CRGT assembly, continuous section sheaths and C-tubes will be managed as MRP-227 Expansion components using the I&E guidelines for CRGTs in WCAP-17451-P, Revision 2, Reactor Internals Guide Tube Wear -
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| Westinghouse Domestic Fleet Operational Projections, November 2018 (Westinghouse Proprietary).
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| o One-time inspections of the core barrel middle axial weld and lower axial weld will be performed in accordance with the guidance in EPRI MRP 2019-009, Transmittal of NEI 03-08 Good Practice Interim Guidance Regarding MRP-227-A and MRP-227, Revision 1-A PWR Core Barrel and Core Support Barrel Inspection Requirements, July 17, 2019 transmitted to the NRC via {{letter dated|date=September 3, 2019|text=letter dated September 3, 2019}} (ADAMS Accession No. ML19249B102).
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| The staff reviewed ETE-NA-2016-0078, Revision 0 and ETE-NA-2018-0008, Revision 0 and verified that initial inspections for all Westinghouse Primary components and Existing Programs components have been completed for NAPS, Unit 1, as specified in the original PWR internals I&E guidelines, MRP-227-A, December 2011 (ADAMS Accession No. ML120170453). Notable I&E results are covered below.
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| The staff reviewed ETE-NA-2019-0003, Revision 0 and ETE-NA-2020-0026, Revision 0 and verified that initial inspections for all Westinghouse Primary components and Existing Programs components have been completed for NAPS,
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| Unit 2, as specified in the original MRP-227-A guidelines. Notable I&E results are covered below.
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| The staff reviewed CR 1048448 and ETE-NA-2016-0078 and confirmed that for NAPS, Unit 1, 1081 baffle-former bolts (BFBs) out of 1088 BFBs total were volumetrically examined by UT in Fall 2016. Seven bolts were unable to be examined by UT since their locking bar welds limited UT probe contact with the bolt surface. Evaluation of UT data identified three bolts with crack indications. A VT-3 visual examination of bolt and locking bar surfaces for the three flawed bolts and the seven untestable bolts identified no visual evidence of degradation. The staff noted that analytical evaluation of the degraded bolting pattern determined that the BFBs satisfied the NRC-approved acceptance criteria in WCAP-17096-NP-A, Revision 2, Reactor Internals Acceptance Criteria Methodology and Data Requirements, August 2016 (ADAMS Accession No. ML16279A320) for ensuring adequate structural margin to support a 10-year reinspection interval.
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| The staff reviewed CR 1118597 and ETE-NA-2019-0003 and confirmed that for NAPS, Unit 2, 1082 BFBs out of 1088 BFBs total were volumetrically examined by UT in Spring 2019. Six bolts were unable to be examined by UT since their locking bar welds limited UT probe contact with the bolt surface. Evaluation of UT data identified 13 bolts with crack indications. A VT-3 visual examination of bolt and locking bar surfaces for the 13 flawed bolts and 6 untestable bolts identified no visual evidence of degradation. The staff noted that analytical evaluation of the degraded bolting pattern determined that the Unit 2 BFBs satisfied the WCAP-17096-NP-A, Revision 2 acceptance criteria for ensuring adequate structural margin to support a 10-year reinspection interval.
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| The staff reviewed CR 1049685 and ETE-NA-2016-0078 and noted that during the Fall 2016 MRP-227-A inspections at NAPS, Unit 1, several guide cards showed wear that required evaluation in accordance with WCAP-17096-NP-A, Revision 2 and WCAP-17451-P, Revision 1, October 2013 (Westinghouse Proprietary). The staff noted that, per the guide card wear evaluation methods in the WCAP reports, the projected wear for the most limiting guide card would not reach the maximum allowable wear threshold until about 2.75 effective full power years (EFPY) after the next scheduled guide card wear measurement for Unit 1. Accordingly, this evaluation determined that all Unit 1 guide cards with wear indications are projected to remain acceptable for at least two operating cycles beyond the next scheduled reinspection.
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| The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
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| The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
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| SLRA AMP B2.1.8, Flow-Accelerated Corrosion Summary of Information in the Application. The SLRA states that AMP B2.1.8, Flow-Accelerated Corrosion, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M17, Flow-Accelerated Corrosion. The SLRA notes that this program is implemented as a Dominion Fleet program and that the program requirements and
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| implementation procedures were previously reviewed by the NRC staff and determined to be acceptable.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Flow-Accelerated Corrosion (FAC) program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020-2311 Aging Management Program Evaluation Report - Flow- Revision 1 Accelerated Corrosion ETE-CME-2020- Erosion Susceptibility Evaluation for Unit 1 Revision 1 0004 ETE-CME-2020- Erosion Susceptibility Evaluation for Unit 2 Revision 1 0005 ETE-CME-2020- Engineering Evaluation for North Anna Systems Revision 0 0013 Excluded from Erosion Program Due to Low Operating Time ETE-CME-2019- North Anna Unit 2 2019 Refueling Outage, Results of Revision 0 0005 Flow-Accelerated Corrosion Program ETE-CME-2018- North Anna Unit 1 2018 Refueling Outage, Results of Revision 0 0002 Flow-Accelerated Corrosion Program ER-AA-FAC-10 Flow-Accelerated Corrosion Program Revision 8 ER-AA-FAC-102 Flow-Accelerated Corrosion (FAC) Inspection and Revision 1 Evaluation Activities ER-AA-FAC-105 Erosion Control Program Revision 0 ER-AA-FAC-1001 Flow-Accelerated Corrosion (FAC) Susceptibility Analysis Revision 6 and Modeling ER-AA-1003 Flow-Accelerated Corrosion (FAC) Operational Revision 6 Experience Reviews CR 1092584 01-SD-348 Pitting on valve body 03/20/2018 CR 1099286 Pipe leaking at elbow downstream of 2-MS-TV-210 06/07/2018 CR 117085 Through-wall pin hole leak on downstream elbow of 2- 11/01/2008 BD-HCV-200B CR 1033983 Steam leak at 2-BD-HCV-200B, pin hole leak in elbow 04/13/2016 CR 1099475 2-BD-HCV-200B has water leakage downstream of valve 06/10/2018 PA 3004801 Review NAPS in response of the Davis-Besse FAC OpE 09/30/2015 PA 7463069 Benchmark lessons learned from IP3 [Indian Point Unit 3] 02/21/2019 FAC failure PA 7558146 Fleet FAC Conference Call 1st Quarter 2019 02/27/2019
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| Document Title Revision / Date PA 7558149 Fleet FAC Conference Call 2nd quarter 2019 06/25/2019 PA 7558151 Fleet FAC Conference Call 3rd quarter 2019 08/20/2019 PA 7558153 Fleet FAC Conference Call 4th quarter 2019 12/11/2019 N-PMTE-2007-0016 Have Engineering inspect and evaluate wall thickness of 02/13/2007 the low-capacity blowdown elbows listed in attachment on a 5-year cycle. Applicable to FAC program NA ETE-CME-2020-0004, Ref 8.11, NAPS Erosion 11/14/2018 Components from CW.xlsx provided e-mail During the audit, the staff verified Dominion Energys statement that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also reviewed the summary description of the program provided in SLRA Appendix A, UFSAR Supplement, Section A1.8, Flow-Accelerated Corrosion. The staff verified this description is consistent with the corresponding program description in GALL-SLR Report Table XI-01.
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| SLRA AMP B2.1.9, Bolting Integrity Summary of Information in the Application. The SLRA states that AMP B2.1.9, Bolting Integrity, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M18, Bolting Integrity. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Bolting Integrity AMP program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date N/A North Anna Operating Experience List Report - Bolting 09/18/2020 Integrity N/A North Anna Operating Experience Detail Report - Bolting 09/18/2020 Integrity CR 560037 Flange bolt failed VT [visual examination] inspection 09/27/2014 CR 522197 Bolting for 1-SW-PPA-1A1 needs to be replaced during 08/01/2013 next scheduled maintenance
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| Document Title Revision / Date CR 388536 Corroded body to bonnet bolting on 2-RS-107 07/21/2010 ETE-SLR-2020-2312 North Anna Subsequent License Renewal Project - Revision 2 Aging Management Program Evaluation Report - Bolting Integrity NAS-2094/NUS- Generic Procurement Specification for Pressure Revision 6 2206 Boundary Threaded Fastener 0-MCM-1006-01 Disassembly and Reassembly of Safety-Related Piping Revision 28 and Component Bolted Flange Joints ER-AA-101 System Engineering Walkdowns Revision 3 ER-AA-NDE-140 Processing of Dominion Energy NDE Data Revision 6 CY-AA-CTL-510 Chemical Control Revision 10 ER-AA-ISI-100 Dominion Inservice Inspection Program Revision 11 The following documents were identified and requested to be provided on the ePortal. These documents were reviewed during the breakout session audit, and any unresolved issues will be evaluated in the SER.
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| : 1) For CR 560037, provide documentation showing resolution of the failed visual examination (VT) inspection.
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| : 2) CR 522197 notes that corroded bolting needs to be replaced and then says engineering evaluated the bolting as acceptable. Provide documentation of the resolution of this issue (either the engineering evaluation finding it acceptable or the completed work).
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| : 3) CR 388536 notes that bolting should be replaced and says it was closed to WO 59102163904. Provide the referenced work order or the documentation showing the bolting was replaced.
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| During the audit, the staff verified Dominion Energys claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, preventive actions, corrective actions, and acceptance criteria program elements of the SLRA AMP are consistent, or consistent with enhancement, with the corresponding element of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observation:
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| The staff reviewed document ETE-SLR-2020-2312 and noted that the document had been revised to incorporate appropriate acceptance criteria for closure bolting in air or gas systems where leakage is difficult to detect.
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| The staff also audited the description of the SLRA Bolting Integrity AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.10, Steam Generators Summary of Information in the Application. The SLRA states that AMP B2.1.10, Steam Generators, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M19, Steam Generators. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Steam Generator (SG) program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision / Date N/A North Anna Operating Experience Detail Report - Steam 07/20/2020 Generators CR 326926 Foreign object found in SG 1A in Unit 1 03/15/2009 CA 131317 Engineering to document in the SG report 03/17/2009 CA 131318 Engineering to report on findings of this foreign material 03/17/2009 CR 347162 NRC RIS 2009-04, Steam Generator Tube Inspection 09/03/2009 Requirements CR 373940 Foreign material found and retrieved from SG 1C in 03/27/2010 Unit 2 CR 374212 Small piece of foreign material in SG 1A in Unit 2 03/30/2010 CR 374737 Foreign material found in secondary side of SG 1B in 04/01/2010 Unit 2 during FOSAR [Foreign Object Search and Retrieval]
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| CA 164743 Document non-retrievable foreign material in the 04/02/2010 Condition Monitoring and Operational Assessment CR 442825 Foreign material identified in SG 1A hot leg in Unit 1 09/13/2011 CA 212765 Maintenance to document removal of foreign material 09/16/2011 CA 212768 Document in the SG report as needed 09/16/2011
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| Document Title/Description Revision / Date CA 215742 Route ACE [apparent cause evaluation] to foreign 10/12/2011 material coordinator for operating experience and trending CA 215743 Update annunciator response for loose parts alarms 10/12/2011 CR 526074 UT exams were conducted on the feedring of SG 1A in 09/15/2013 Unit 1 CA 270199 Engineering review prior to visual and UT inspection 09/30/2013 results for Unit 2 SG feedrings CR 526498 Possible loose part in SG 1A in Unit 1 09/19/2013 CA 269538 Review foreign material concern with SG 1A in Unit 1 09/20/2013 against foreign material program CR 1031026 Foreign object has been reported in SG 1C cold leg in 03/18/2016 Unit 2 CA 3026944 Engineering to fully disposition foreign object in SG 1C 03/19/2016 cold leg CA 3026952 Engineering to determine a feasible method to retrieve 03/19/2016 the foreign object during future refueling outage CA 3026966 Maintenance to document disposition of foreign object 03/20/2016 not retrieved CR 1080530 NSAL-12-1 Rev 1, Steam Generator Channel Head 10/11/2017 Degradation CA 3067580 Engineering to evaluate NSAL-12-1 Rev 1 10/12/2017 CR 1092977 Piece of foreign material was identified in the feedring of 03/24/2018 SG 1B in Unit 1 CA 3162721 Engineering to document removal of foreign material and 03/25/2018 evaluation of any damage CA 3162722 Engineering to determine source of foreign material and 03/25/2018 evaluate any extent concerns CA 3162723 Maintenance to review this issue against foreign material 03/25/2018 program requirements ETE-SLR-2020-2313 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report - Steam Generators ER-AA-NDE-125 Steam Generator Tube Examination Independent Revision 1 Qualified Data Analyst Requirements and 03/24/2014 Responsibilities TRM 3.4.4 Primary-to-Secondary Leakage Revision 101 10/02/2014 ETE-CEP-202-1003 Identification and Evaluation of RCS Alloy 600 Locations Revision 0
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| - Steam Generator Locations 03-1274768-003 Secondary Side Visual Inspection and Loose Parts Revision 0 Retrieval Procedure for Heat Exchangers 54-ISI-400-023 Nondestructive Examination Procedure Multi-Frequency Revision 0 Eddy Current Examination of Tubing 1-PT-46.3A Primary-To-Secondary Leak Rate Determination Revision 16
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| Document Title/Description Revision / Date ER-AA-SGP-10 Steam Generator Program Description Revision 0 03-1250267-003 Steam Generator Upper Internals Inspection Procedure Revision 0 for Recirculating Steam Generators CY-AP-PRI-100 Primary System Chemistry Revision 10 ER-AA-SGP-101 Steam Generator Program Revision 0 ER-AA-SGP-102 Steam Generator Degradation Assessment Revision 0 ER-AA-SGP-103 Steam Generator Condition Monitoring and Operational Revision 0 Assessments CY-AP-SEC-200 Secondary System Chemistry Revision 8 ETE-NA-2019-0033 North Anna Unit 1 - Steam Generator Degradation Revision 0 Assessment and Inspection Interval Review - September 2019 Refueling Outage (N1R27)
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| ETE-NA-2019-1001 North Anna Unit 2 Steam Generator Integrity Revision 0 Degradation Assessment (R26)
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| ETE-NA-2018-0003 North Anna Unit 1 Spring 2018 Steam Generator Revision 0 Condition Monitoring and Operational Assessment ETE-SLR-2020-2604 North Anna Subsequent License Renewal Project - Revision 1 Further Evaluation Recommended Report - SRP Section 3.1 - Reactor Vessel, Internals, and Reactor Coolant System N/A North Anna, Unit 1, Submittal of Steam Generator Tube 09/04/2018 Inspection Report (ADAMS Accession No. ML18255A061)
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| N/A North Anna, Unit 2, Steam Generator Tube Inspection 06/24/2019 Report (ADAMS Accession No. ML19179A075)
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| During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Steam Generator program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.11 Open-Cycle Cooling Water System Summary of Information in the Application. The SLRA states that AMP B2.1.11, Open-Cycle Cooling Water System, is an existing program with an exception that is consistent with the program elements in GALL-SLR Report AMP XI.M20, Open-Cycle Cooling Water System. To
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| verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER. During the audit, the staff reviewed the exception associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Open-Cycle Cooling Water program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date Chiller HX [heat exchanger] Clean-Inspect and RSHX Multi-year N/A [recirculation spray heat exchangers] Clean-Inspect Flow record from Test 2013-2019 WO 59102999311 Perform Eddy current Testing of 02-RS-E-1D-HTEXCH 09/28/2017 CR 1010918 Through-wall leak in 1B2 Spray Array Piping 09/2015 CR 1010927 TW leak in 2A2 Spray Array Piping 09/2015 CR 1076052 Nozzle clogged 08/2017 CR 1082583 1 Nozzle and 9 drains inoperable 10/2017 CR 1088883 1 nozzle and 8 drains clogged. 01/2018 North Anna Subsequent License Renewal Project -
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| ETE-SLR-2020-2314 Aging Management Program Evaluation Report - Open- Revision 2 Cycle Cooling Water System Service Water System Inspection and Maintenance VPAP-0811 Revision 6 Program 0-PT-75.11 Service Water System Reservoir Components Revision 8 0-PT-75.11 Service Water System Reservoir Components Revision 9 0-PT-75.14A Service Water Spray Array Wall Thickness Monitoring Revision 14 Generic Letter 89-13 Service Water System Testing 0-PT-75.15 Revision 8 Requirements Coordination ER-NA-SYS-320 Generic Letter 89-13 Program Revision 6 Open Cooling Water Systems Chemistry Specifications CH-99.710 Revision 0 and Action Levels CH-99.711 Open Cooling Water Systems Chemistry Strategic Plan Revision 0 CA to Engineering to review requirement for 1- and 2-CA 3033389 inch drains on spray arrays and initiate any required 6/10/2016 PT/PM/procedure changes 11715-FP-5AQ, SH-Service Water Reservoir Spray Piping Plans & Sections Revision 1 001
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| During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA Open-Cycle Cooling Water System AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| The staff also verified Dominion Energys claim that aspects of the detection of aging effects program element not associated with the exception identified in the SLRA are consistent with the corresponding program element in the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP for the Open-Cycle Cooling Water System provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.12 Closed Treated Water Systems Summary of Information in the Application. The SLRA states that AMP B2.1.12, Closed Treated Water Systems, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M21A, Closed Treated Water Systems.
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| To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities.
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| During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Closed Treated Water program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date Chilled Water Conductivity Exceeded Action Level 2 for CR 330564 05/05/2009 30 Days Coolant Water Leakage from 1H EDG [emergency CR 1044899 08/17/2016 diesel generator] Leak Inspect U2 Neutron Shield Tank leakage at the N43 CA 019440 10/17/2007 Neutron Detector Inspect the Unit 2 NST [neutron shield tank] during the CA 3163485 Spring 2019 RFO [refueling outage] and document 03/26/2018 leakage trend U2 H EDG phosephate analysis exceeded action level CR 1087584 01/10/2018 2
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| CR 1048379-01-NS-P-Neutron Shield Tank Pump has Seal Leakage 09/23/2016 1A WO 59103017605 Mechanical Seal Repair 06/01/2020
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| Document Title Revision / Date North Anna Subsequent License Renewal Project -
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| ETE-SLR-2020-2315 Aging Management Program Evaluation Report - Revision 2 Closed Treated Water Systems Closed Cooling Water Systems Chemistry CH-99.700 Revision 0 Specifications and Action Levels Closed Cooling Water Systems Chemistry Strategic CH-99.701 Revision 0 Plan 3002000590 EPRI Closed Cooling Water Chemistry Guideline Revision 2 Implementation of Activities Performed by License ER-AA-AMP-101 Revision 11 Renewal Aging Management Coordinators XI.M21A Enhancement Summary N/A N/A New Workflow Procedure Outline N/A N/A Process Flow Diagram for New Workflow Procedure N/A Justification for Increasing the Chloride and Fluoride ET-N-07-0008 Concentration in Component Cooling and Neutron Revision 1 Shield Tank Cooling During the audit, the staff verified that the program elements of the SLRA Closed Treated Water System AMP that Dominion Energy declared were consistent are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit, the staff made the following observation:
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| The staff reviewed ET-N-07-0008 and noted that concentrations for chromates were exceedingly high and beyond the Action Levels promulgated in CH-99.700 but deemed acceptable per reviewed ET-N-07-0008. The staff also noted that CH-99.700 for corrective actions refers to EPRI Closed Cooling Water Guideline, Revision 2 when limits of tracked parameters are exceeded, with an allowed deviation for chromates as discussed in CH-99.701.
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| The staff also audited the description of the SLRA AMP for the Closed Treated Water Systems provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.13, Inspection of Overhead Heavy Load and Light Load Handling Systems Summary of Information in the Application. The SLRA states that AMP B2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems.
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| To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems program.
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| The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date N/A North Anna Operating Experience List Report - 10/1/2020 Inspection of Overhead Heavy Load and Light Load Handling Systems N/A North Anna Operating Experience Detail Report - 10/01/2020 Inspection of Overhead Heavy Load and Light Load Handling Systems CR 508620 WO needed to stencil/label the aux bldg. 259 and 279 03/20/2013 monorails Reviewed within NAPS OpE Detail Report CR 422309 1-MH-CRN-9A has a crack on the rail track switch 04/14/2011 mounting plate Reviewed within NAPS OpE Detail Report CR 318545 Programmatic work request for LR [license renewal] 12/31/2008 required polar crane girder inspections CR 318848 Programmatic work request for LR required Unit 2 polar 01/05/2009 crane girder inspection ETE-SLR-2020-2316 North Anna Subsequent License Renewal Project - Revision 2 Aging Management Program Evaluation Report -
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| Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 0-MPM-1301-01 Frequent and Periodic Inspections of 1-MH-CRN-1 and Revision 22 2-MH-CRN-1 0-MPM-1303-01 Frequent and Periodic Inspections of Monorails and Revision 27 Overhead Hoists, 1-MH-CRN-6A/B, 2-MH-CRN-6A/B, 1-MH-CRN-8, 1-MH-CRN-19, 2-MH-CRN-19, 1-MH-CRN-26, 1-MH-CRN-30, 1-MH-CRN-49, and 1-MH-CRN-50 MA-AA-OCR-101 Overhead Cranes/Hoists Revision 5 MA-AA-101 Lifting and Material Handling Revision 26 VPAP-0809 NUREG-0612 Heavy Load Program Revision 11 0-MPM-1304-01 Inspection and Repair of Refueling Lifting Devices Revision 16 NAS-142 Specification for Reactor Containment Crane for North Revision 3 Anna Power Station 06/10/1977
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| Document Title Revision / Date 0-MPM-1308-01 Frequent and Periodic Inspection of 1-MH-CRN-51 and Revision 13 2-MH-CRN-51 The following documents were identified and requested to be provided on the ePortal. These documents were reviewed during the breakout session audit and any unresolved issues will be evaluated in the SER.
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| : 1) CR 508620 notes that stenciling needed to be applied to the referenced monorails.
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| Provide documentation showing this was done or why it was unnecessary.
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| : 2) CR 422309 identifies a crack in an I-beam. Provide documentation showing how this issue was resolved.
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| : 3) CR 318545 and CR318848 discuss inspections that resulted from initial LR. Provide documentation of the results of the inspections and the engineering evaluation mentioned in the CRs.
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| During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit, the staff reviewed NAS-142, and noted that the interior surface of the polar crane box girders were coated with a 2.0 mil epoxy coating during construction. The staff also reviewed CR 318848 associated with the initial license renewal polar crane inspections and noted that the results of the inspections identified minor patches of slight discoloration on a coated surface, indicative of surface rust.
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| The staff also audited the description of the SLRA Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.14, Compressed Air Monitoring Summary of Information in the Application. The SLRA states that AMP B2.1.14, Compressed Air Monitoring, program is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M24, Compressed Air Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Compressed Air Monitoring program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 1080205 1-GOP-223.1 Acceptance Criteria Item Not Met 10/06/2017 CR 437120 WO Needed for UT readings on 02-IA-TK-4A 08/08/2011 CR 442638 Instrument Air Leak Upstream of 2-IA-905 09/13/2011 CR 443285 IA [instrument air] Line Leak downstream of 1-CN-LC- 09/16/2011 109 CR 457662 1-MS-TV-101B has an instrument air leak near the 01/02/2012 actuator CR 475762 1-MS-PCV-101C instrument air tubing appears to be 05/18/2012 cracked and leaking CR 556903 IA supply filter inside 1-EP-CB-42 for FB [fuel building] 08/25/2014 ventilation found hosing cracked/leak CR 560292 2-IA-C-2A should be internally inspected next outage 09/29/2014 ETE-SLR-2020-2317 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report -
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| Compressed Air Monitoring 0-GEP-226 Instrument Air Performance Testing Revision 4 0-GOP-223 Performance Verification of SWPH Instrument Air Revision 0 System 1-GOP-223.1 Containment Instrument Air Compressor Testing Revision 3 1-GOP-227 Desiccant Instrument Air Dryer 1-IA-D-1 Performance Revision 0 Testing ER-AA-AMP-101 Implementation of Activities Performed by LR Aging Revision 11 Management Coordinators WM-AA-100 Work Management Revision 34 50-280 Virginia Power Letter to NRC, Response to [Generic 02/21/1989 Letter] GL 88-14 91-576 Virginia Power Letter to NRC, Response to GL 88-14 10/16/1991 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP Compressed Air Monitoring Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.15, Fire Protection Summary of Information in the Application. The SLRA states that AMP B2.1.15, Fire Protection, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M26, Fire Protection. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements to the GALL-SLR Report AMP in the SER.
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| Audit Activities.
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| During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Fire Protection program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision / Date N/A North Anna Operating Experience Detail Report - Fire 11/14/2019 Protection CR 446442 Hair-line crack observed in marinite board under cable 10/06/2011 tray in Unit 2 WO 59102376706 Replace cracked marinite board on cable tray in Unit 2 10/22/2011 CR 1038564 NOD [Notice of Deficiency] Audit finding 16-04-01NS: 05/26/2016 Admin control not effective for changes for license renewal program CR 464699 Torn door seals and seals need replacing in Unit 1 03/01/2012 WO 59102339028 Door and closure inspection Unit 1 03/01/2012 CR 549226 CO2 [carbon dioxide] louvers for Unit 2 emergency diesel 05/16/2014 generator appear to have counterweight issues WO 59102729714 Counterweight repair 05/14/2016 CR 441322 Caulking degraded on the southwest corner of a Unit 1 09/03/2011 firewall WO 59102349557 Caulking degraded on the southwest corner of Unit 1 10/27/2011 firewall WO 59102898739 Unit 2 Control Room Halon System Flow Test 03/14/2017 WO 59102983040 Unit 1 Low-Pressure CO2 - Total Flooding Zones 03/01/2018 Functional Test and Puff Test WO 59203131680 Fire Protection - High Pressure CO2 System Flow Test 11/15/2019 WO 59203139771 Fire Protection - Halon System Flow Test - Unit 2 01/24/2020 Emergency Switchgear Room WO 59102982570 Fire Door Inspection - Service Building 11/29/2017 WO 59103032618 Fire Door Inspection - Turbine Building, Control Room, 04/12/2018 and Office Area
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| Document Title/Description Revision / Date WO 59203275054 Fire Door Inspection - Auxiliary Building 01/21/2020 WO 59203297251 Main Control Room Pressure Boundary Door Seal 09/13/2019 Inspection WO 59076684701 Unit 1 Fire Protection - Fire Damper Functional 06/15/2011 Operability Test WO 59101842759 Unit 2 MPM [mechanical preventative maintenance] 12/31/2009
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| /1YR/Fire Damper Inspection/Lube WO 59102501042 Unit 1 Fire Damper Inspection 01/17/2014 WO 59102883577 Unit 1 Fire Damper Inspection 03/02/2017 WO 59203277550 Unit 1 Fire Damper Inspection 04/16/2020 WO 59102914456 Periodic Inspection - Visual inspection of auxiliary 05/30/2017 building fire retardant coatings and cable tray fire stops WO 59102965506 Periodic Inspection - Visual inspection of Unit 2 10/06/2017 containment radiant energy shields, cable tray firestops, and RCP oil collection systems WO 59103029876 Periodic Inspection - Visual inspection of Unit 1 04/11/2018 containment radiant energy shields, cable tray firestops, and RCP oil collection systems WO 59103088647 Periodic Inspection - Visual inspection of auxiliary 01/31/2019 building fire retardant coatings and cable tray fire stops WO 59103130078 Periodic Inspection - Visual inspection of Unit 2 04/02/2019 containment radiant energy shields, cable tray firestops, and RCP oil collection systems WO 59203143057 Periodic Inspection - Visual inspection of Unit 1 09/23/2019 containment radiant energy shields, cable tray firestops, and RCP oil collection systems WO 59000570679 Periodic Inspection - Penetration Seals 05/09/2007 WO 59101973833 Periodic Inspection - Penetration Seals 05/15/2013 WO 59102279117 Periodic Inspection - Penetration Seals 03/07/2019 WO 59102279119 Periodic Inspection - Penetration Seals 04/01/2020 WO 59102243602 Periodic Inspection - Penetration Seals 03/29/2016 ETE-SLR-2020-2119 North Anna Subsequent License Renewal Project - Revision 0 Integrated Plant Assessment Report - Auxiliary Systems
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| - Fire Protection System N/A AMP XI.M26 Enhancement Summary N/A (portal modified date 09/08/2020)
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| ETE-SLR-2020-2318 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report - Fire Protection
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| Document Title/Description Revision / Date ETE-SLR-2019-2004 North Anna Subsequent License Renewal Project - Revision 1 Regulated Event Report - 10 CFR 54.4(a)(3) Fire Protection CM-AA-FPA-100 Fire Protection/Appendix R (Fire Safe Shutdown) Revision 14 Program 0-PT-105.1.4A Fire Protection System - Fire Barriers Revision 15 0-PT-105.1.4B Revision 13 0-PT-105.1.4C Revision 12 0-PT-105.1.4D Revision 12 0-PT-105.1.4E Revision 13 N/A Technical Requirements Manual Rev 122-7.0 and 12.2- Revision 121 Fire Protection 08/28/2019 ETE-SLR-2020-2110 North Anna Subsequent License Renewal Project - Revision 1 Integrated Plant Assessment Report - Structures and Component Supports - Structural Commodities ETA-SLR-2020-2607 North Anna Subsequent License Renewal Project - Revision 2 Further Evaluation Recommended Report - SRP Section 3.3 - Auxiliary Systems CG0000908627 North Anna Power Station Appendix R Report Revision 46 ET-CEP-00-0002 Evaluation of the Seismic Separation (Rattlespace) Revision 1 Between Various Concrete Walls SAR PIR1011181 Perform an informal self-assessment on License May 2016 Renewal MSRC PIR1112472 NANN and MPS to Perform an Effectiveness Review of April 2019 all Initial License Renewal AMAs/AMPs During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the preventive actions, detection of aging effects, and acceptance criteria program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| The staff also verified Dominion Energys claim that aspects of the monitoring and trending and corrective actions program elements not associated with the enhancements identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.
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| In addition, the staff found that for the scope of program and parameters monitored or inspected program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit, the staff made the following observations:
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| Loss of material for the reactor coolant pump (RCP) motor oil collection system will not be managed by AMP XI.M26.
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| Fire barrier doors will not be evaluated as miscellaneous structural commodities.
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| However, loss of material due to wear for steel fire rated doors exposed to air will be managed by AMP XI.M26.
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| The fireproofing and fire barrier materials used in containment are stainless steel radiant energy shields for equipment and conduits, Marinite boards and Marinite splice boards for cable tray fire stops, silicon foam (i.e., Dow Corning Q3-6548 RTV Silicone Foam), Cerafiber damming material, concrete elements, and Thermo-lag.
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| The stainless steel portion of radiant energy shields will be managed by AMP XI.S6, Structures Monitoring. However, the fireproofing/fire barrier material portion of radiant energy shields will be managed by AMP XI.M26.
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| During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Fire Protection program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.16, Fire Water System Summary of Information in the Application. The SLRA states that AMP B2.1.16, Fire Water System, is an existing program with exceptions and enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M27, Fire Water System. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exceptions and enhancements associated with this AMP. The staff will document its review of the exceptions and enhancements to the GALL-SLR Report AMP in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Fire Water System program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision / Date N/A North Anna Operating Experience Detail Report - Fire Water System PI-N-2003-4071 All fire pumps started due to an apparent leak in the fire 11/16/2003 system Category 2 RCE Underground 12 Fire Main Rupture 07/06/2001 Report No. PI-N-2001-1956-E1 Plant Issue Large break occurred in the fire main outside the 07/06/2001 Resolution N-2001- auxiliary boiler room 1956-R14
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| Document Title/Description Revision / Date WO 0048727302 Replace fire piping (auxiliary boiler room), Unit 2 2007 WO 0048727305 Perform tie in immediately downstream, Unit 2 2007 2-PT-109.1.3 Fire Protection-Deluge and Sprinkler H2 Seal Oil Unit 03/04/2019 2-PT-109.1.2 Fire Protection-Deluge and Sprinkler System for 03/03/2019 Transformer 2-PT-109.1.1 Fire Protection-Deluge System-Turbine Oil and Oil 03/04/2019 Purifier 1-PT-109.1.3 Fire Protection-Deluge and Sprinkler System H2 Seal Oil 09/30/2019 Unit 1-PT-109.1.2 Fire Protection-Deluge and Sprinkler System for 09/08/2019 Transformer 1-PT-109.1.1 Fire Protection-Deluge System-Turbine Oil and Oil 09/29/2019-1 Purifier 0-PT-103.2 Fire Protection - Two Inch Drain Test 05/16/1996 0-PT-109.2 Fire Suppression Water System - System Flush 12/18/2017 0-PT-100.6 Fire Protection - Main Fire Loop Flow Test 10/17/2019 0-PT-100.2 Fire Protection Pumps - Annual Testing 07/01/2020-1 2-PT-105.4.1 Fire Protection - Hose Station Flow Test 09/25/2017 0-PT-105.6 Fire Protection - Flow of Standpipe Connections Located 10/11/2018 Below Level of Fire Main 2-PT-109.1.4 Fire Protection - Sprinkler Systems 12/13/2017 1-PT-102.2.3 Service Building Cable Vault Sprinkler System - Air Flow 07/28/2017 Test 0-PT-109.1.5 Fire Protection - Auxiliary Building and Service Building 06/11/2020 Cable Vault and Tunnel Sprinkler Systems Functional Test and Inspections CR 569865 Adjust pipe pitch on Unit 2 oil purifier fire protection- 01/20/2015 deluge system WO 59102819810 Adjust pipe pitch on Unit 2 oil purifier fire protection- 01/20/2015 deluge CR 564364 Hole in Unit 2 deluge system elbow 11/04/2014 CA 293166 Evaluate concern with hole in Unit 2 deluge system 11/05/2014 elbow for aging management CA 296407 Revise 0-PT-105.4 01/20/2015 CA 296408 Revise 2-OP-1B 01/20/2015 CA 296409 Revise 2-PT-109.1.4 01/20/2015
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| Document Title/Description Revision / Date WO 59102800074 Replacement of elbow No Date CR 1068879 Corrosion products found inside of valve bodies, Unit 1 05/16/2017 CA 3057930 Engineering to document current fire protection 05/18/2017 strategies to minimize corrosion WO 59049830202 Post indicator valve replacement, Unit 1 05/15/2017 WO 59052375202 Post indicator valve replacement, Unit 1 05/15/2017 CR 1013473 Unsatisfactory license renewal inspection for station 10/14/2015 blackout fire protection system CA 3012886 Engineering to review for impacts to license 10/16/2015 renewal/aging management program CR 566511 Evidence of buried fire protection pipe leak at intake 12/01/2014 structure (jockey pump piping)
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| NNOE001416 OpE draft assignment for evidence of buried fire 12/02/2014 protection pipe leak at intake structure WO 59102741979 1-FP-43 suspected of leaking by 03/22/2017 WO 59102806117 Evidence of buried fire protection pipe leak at intake No Date structure CA 291324 Review fire protection piping for license renewal 10/10/2014 CR 569417 Perform internal inspection of motor-driven fire pump 01/13/2015 discharge pipe WO 59102816760 Disassembly of valve to perform internal inspection of 03/21/2017 discharge pipe CR 1143488 Low point within drain in Units 1 and 2 Station Service 03/19/2020 Transformers 1C Deluge Sprinkler Piping CA 7881133 Engineering to verify no piping supports/hanger 03/23/2020 modifications needed and initiate any necessary action CR 1143491 Units 1 and 2 Hydrogen Seal Oil Deluge Sprinkler Piping 03/19/2020 CA 7881134 Engineering investigate/initiate REA to address any 03/23/2020 required engineering solution CR 1143494 Unit 1 turbine building lube oil purifier fire protection drain 03/19/2020 plug needs to be rotated over WO 59203306507 Unit 1 turbine building lube oil purifier fire protection drain No Date plug needs to be rotated over CR 487704 License renewal as-found condition of Unit 1 existing fire 09/11/2012 protection piping pump unsatisfactory WO 59102311523 Replace Unit 1 discharge piping 09/13/2012 CR 1039515 Through-wall leak on fire protection elbow of Unit 2 06/09/2016 sprinkler line CA 3033412 Engineering to review for impacts to LR/Aging 06/10/2016 Management Program
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| Document Title/Description Revision / Date WO 59102984993 Through-wall leak on fire protection elbow Unit 2 06/10/2016 WO 59102514393 Replacement of the Unit 1 under roadway piping No Date WO 59102581705 Unit 2 fire protection-deluge drain header plugged 04/08/2013 WO 59102236939 Drain valve clogged during fire protection PT in rack 12/19/2011 room, Unit 1 WO 59203281795 Tail pipe plugged, Unit 1 04/30/2019 WO 59102341887 Replace sprinkler head, Unit 1 08/24/2011 WO 59102341697 Replace sprinkler head, Unit 2 08/25/2011 WO 59101845958 Leaking sprinkler head in security building, Unit 1 01/17/2009 WO 59103070483 Pipe elbow downstream has slight leak, Unit 1 No Date WO 59102816758 Replace Unit 1, Turbine Bldg, 12 fire protection supply 09/27/2019 piping WO 59102790742 Replace Unit 2 10 fire protection piping due to interior No Date build-up and corrosion WO 59102790702 Replace Unit 2 remaining 12 piping - interior build-up No Date and corrosion CR 569869 Programmatic work order requested to perform UT on 01/20/2015 Unit 2 H2 seal oil deluge piping ER-AA-5000 Nuclear Nondestructive Examination Request - Unit 2 11/12/2019 H2 seal oil fire protection-deluge system piping WO 59102819440 UT on Unit 2 H2 seal oil deluge piping No Date N/A Fire Protection Pre-Actuated Dry Pipe Walkdown 07/29/2020 WO 59102271196 Unit 2 service water traveling screen chain and 12/12/2016 basket/tray replacement WO 59102271193 Unit 1 service water traveling screen chain and 03/21/2020 basket/tray replacement WO 59102271194 Unit 1 service water traveling screen replacement 07/08/2013 WO 59102271195 Unit 2 service water traveling screen chain and 12/07/2017 basket/tray replacement WO 59052137001 Unit 1 fire pump replacement 05/24/2017 WO 59102139366 Unit 2 deluge system strainer inspection 06/27/2016 WO 59101816856 Unit 2 deluge system strainer inspection 05/26/2010 WO 59080154101 Unit 1 fire system strainer inspection 12/22/2008
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| Document Title/Description Revision / Date WO 59101829078 Unit 1 turbine building fire protection system strainer 01/29/2015 inspection WO 59203280330 Unit 1 fire hydrant gate valve inspections 11/27/2019 WO 59101915127 Perform fire protection tie in upstream, Unit 1 12/12/2012 WO 59101915066 Perform fire protection tie in downstream, Unit 1 11/20/2012 RE 523958 18M PT: FIRE PROT-SPRINKLER SYSTEMS No Date RE 525137 3YR PT: FP-HOSE STATION FLOW TEST No Date RE 525013 3YR PT: FIRE PROT-MAIN FIRE LOOP FLOW TEST No Date RE 525151 5 YR PT: FIRE SUPP. WTR SYS-SYSTEM FLUSH No Date RE501594 FIRE SYSTEM STRAINER INSPECTION No Date RE501641 DELUGE SYSTEM STRAINER INSPECTION No Date RE 95457 6M TRAVELING SCREEN INSPECTION AND LUBE 08/12/2020 FOR 01-CW-1B-FILTER eWP WO 59203303242 6M TRAVELING SCREEN INSPECTION AND LUBE No Date FOR 01-CW-1B-FILTER eWP RE95465 eWP 1-CW-S1B JANUARY ANNUAL PREVENTITIVE 01/11/2019 MAINTENANCE LUBRICATION INSPECTION WO 59203136796 eWP 1-CW-S1B JANUARY ANNUAL PREVENTITIVE No Date MAINTENANCE LUBRICATION INSPECTION RE95473 eWP PERFORM 1 YEAR FEBRUARY LUBRICATION 02/11/2016 AND INSPECTION FOR 01-CW-S-1B-FILTER WO 59102697229 eWP PERFORM 1 YEAR FEBRUARY LUBRICATION No Date AND INSPECTION FOR 01-CW-S-1B-FILTER RE500165 LUBRICATE/INSPECT TRAVELING SCREEN 04/15/2019 WO 59203136623 LUBRICATE/INSPECT TRAVELING SCREEN No Date RE505876 SCREEN/INTAKE BAY SWPMP INSP 07/29/2010 WO 59072218201 SCREEN/INTAKE BAY SWPMP INSP No Date ETE-SLR-2020-2119 North Anna Subsequent License Renewal Project - Revision 0 Integrated Plant Assessment Report - Auxiliary Systems
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| - Fire Protection System ETE-SLR-2020-2319 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report - Fire Water System 0-PT-100.6 Fire Protection - Main Fire Loop Flow Test Revision 8
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| Document Title/Description Revision / Date 0-PT-105.4 Fire Protection - Hose Station Flow Test Revision 7 0-PT-109.2 Fire Suppression Water System - System Flush Revision 8 1-PT-109.1.2 Fire Protection-Deluge and Sprinkler System for Revision 15 Transformer 1-PT-109.1.4 Fire Protection - Sprinkler Systems Revision 28 0-PT-100.6 Fire Protection - Main Fire Loop Flow Test, Markup Revision 8 0-PT-105.4 Fire Protection - Hose Station Flow Test, Markup Revision 7 0-PT-105.6 Fire Protection - Flow of Standpipe Connections Located Revision 1 Below Level of Fire Main, Markup 1-PT-105.4.1 Fire Protection - Hose Station Flow Test, Markup Revision 4 2-PT-105.4.1 Fire Protection - Hose Station Flow Test, Markup Revision 4 CM-AA-FPA-100 Fire Protection/Appendix R (Fire Safe Shutdown) Revision 14 Program, Markup N/A XI.M27 Enhancement Summary No Date STD-GN-0001, Attachment 11, Underground Fire Protection Piping 2013 Attachment 11 Replacement/North Anna/Units 1 and 2 STD-GN-0001, Attachment 2, Underground Fire Protection Piping 2005-2006 Attachment 2 Replacement/North Anna/Units 1 and 2 STD-GN-0001, Attachment 2, Fire Protection Hydropneumatic System 2006 Attachment 2 Upgrades/North Anna Power Station Units 1 and 2 ET N 02-130 Replacement of existing Cast Iron Fire Protection Piping Revision 0 with Ductile Iron - West Side of Yard NESML-Q-473 NES Materials Engineering Laboratory Materials Analysis 10/15/2001 Report 0-MPM-0400-24 Frequent and Periodic Inspections and Lubrication of Fire Revision 16 Hydrant Gate Valves & Post Indicator Valves N/A Service Water Traveling Screen History No Date Specification NAI- Installation Specification for Underground Fire Protection Revision 0 0034 Systems During the audit, the staff verified that the program element that Dominion Energy declared was consistent, the preventive actions program element of the SLRA AMP, is consistent with the corresponding element of the GALL-SLR Report AMP.
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| The staff also verified Dominion Energys claim that aspects of the parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements not associated with the exceptions and enhancements identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.
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| In addition, the staff found that for the scope of program, and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit, the staff made the following observations:
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| The piping pitch adjustment for the Unit 2 lube oil purification and hydrogen seal oil piping, and installation of a drain valve on the Unit 2 hydrogen seal oil piping is scheduled to be performed in 2021. This work is related to Enhancement 5 to AMP XI.M27.
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| There is an air-water interface inside the hydropneumatic tank. The air-water interface moves up and down, therefore, aging affects/mechanisms for raw water over the entire internal surface of tank will be managed.
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| Fire hoses are not managed by AMP XI.M27. Fire hoses are replaced based on condition.
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| Enhancement 7 to AMP X.M27 to test sprinklers that have been exposed to water is a one-time test.
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| The staff also audited the description of the SLRA Fire Water System program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.17, Outdoor and Large Atmospheric Metallic Storage Tanks Summary of Information in the Application. The SLRA states that AMP B2.1.17, Outdoor and Large Atmospheric Metallic Storage Tanks, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL SLR Report AMP and the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Outdoor and Large Atmospheric Metallic Storage Tanks program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 1022420 Request work order to perform internal inspection of 1- 12/29/2015 CN-TK-1 for License Renewal CR 579764 1-CN-TK-1 WO needed for rain water leakage 05/15/2015 CR 554222 Water leakage from pipe penetration at U-2 ECST 07/17/2014
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| [emergency condensate storage tanks]
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| CR 506887 U-1 Casing Cooling Tank insulation is deteriorating 02/28/2013 CR 1042142 Evidence of rain water intrusion between 2-CN-TK-1 and 07/12/2016 missile shield ETE-SLR-2020-2320 North Anna Subsequent License Renewal Project - Aging Revision 0 Management Program Evaluation Report - Outdoor and Large Atmospheric Metallic Storage Tanks CM-AA-CTG-104 Condition Assessment of Internally Coated/Lined Tanks, Revision 3 Components, and Pipes subject to Immersion Service ER-AA-AMP-101 Implementation of Activities Performed by License Revision 11 Renewal Aging Management Coordinators Drawing 11715-3.22- Case Cooling Tank (Page 1 drawing) Revision 2 26b SH-001 Drawing 11715-N- Case Cooling Tank (Page 2 drawing) Revision 2 308 Drawing 11715-BK- Calculation - Casing Cooling Tank and Pump House 02/24/1978 5AF Drawing 11715-FC- FDN Plan and Details RWST [refueling water storage Revision 9 12D tank] and Misc Equipment (Drawing Page 1)
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| Drawing 11715-GV- Refueling Water Chemical Addition Tank (Drawing) Revision 4 65A ETE-SU-2011-0024 License Renewal Inspection for RWST and CAT Revision 0
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| [chemical addition tank]
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| Drawing 11715-FC- FDN Plan and Details ECST and Aux FWPH [feedwater Revision 19 12B pump house] (Drawing)
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| Drawing 11715-FC- FDN Plan and Details ECST (Drawing Page 1) Revision 7 12C Drawing 11715-FC- ECST Roof Manway Details (Drawing Page 4) Revision 9 12D Drawing 11715-FV- 110,000 Gallon Condensate Storage Tank Revision 9 12B N/A AFWPH [auxiliary feedwater pump house] ECST No Date Concrete Wall Drain Photo 1 and 2 N/A Upper Manway Photo of ECST No Date Drawing 11715-FC- FDN Plan and Details (Drawing Page 6) Revision 9 12F Drawing 11715-FV- RWST (Drawing Page 1) Revision 10 44A ET-CCE-10-0001 RWST Inspection Bottom Thickness Criteria Revision 0
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| During the audit, the staff verified Dominion Energys claim that the scope of program, and monitoring and trending program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified Dominion Energys claim that aspects of the preventive action, parameters monitored or inspected, detection of aging effects, acceptance criteria, and corrective actions program elements not associated with the exception identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP. In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing a RAI in order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP. During the audit of the operating experience program element, the staff reviewed a search results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OpE in the SER.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Outdoor and Large Atmospheric Metallic Storage Tanks provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.18, Fuel Oil Chemistry Summary of Information in the Application. The SLRA states that AMP B2.1.18, Fuel Oil Chemistry, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Fuel Oil Chemistry program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR1015015 1-SEC-TK-2 Particulate Greater than 10 mg/L 10/22/2015 CR1016651 2-EG-TK-2H Fuel Oil Sample Particulate Out of 11/02/2015 Specification CR1042672 1-FP-P-P-2 Fuel Dilution Percentage Upward Trend 07/19/2016 CR324598 2-EG-TK-2J Particulate Results Were out of Specification 02/24/2009 High at 13.19 mg/L CR555120 Water and Sediment Found in Fuel Oil Samples During 07/30/2014 0-PT-84.1
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| Document Title Revision / Date ETE-SLR-2020-2321 North Anna Subsequent License Renewal Project - Aging 09/02/2020 Management Program Evaluation Report - Fuel Oil Chemistry CY-AA-AUX-310 Diesel Fuel Oil Sampling and Testing (Fleet Procedure) Revision 12 CR-579471 Low Sulfur Fuel Oil could degrade the copper Fuel Oil 05/12/2015 Supply line to 1-FP-P-2 CH-32.115 Fuel Oil Sampling Revision 2 1-PT-89.1A Operations Periodic Test Revision 21 1-PT-89.1B Fuel Oil Sampling - 1J EDG Day Tank and 2b Revision 18 Underground Tank 2-PT-89.5B Cleaning of Emergency Diesel Generator Day Tank 2- Revision 3 EG-TK-2J Tech Specs 3.8.1 Tech Specs 3.8.1 AC [alternating current] Sources No Date Operating for North Anna Units 1 and 2 CR 1038564 NOD Finding 16-0401NS Admin Control Not Effective for 05/26/2016 Changes for License Renewal Program CR 59102773868 Replace Sec. Diesel Gen. Fuel oil Supply Tank per DC 12/18/2014
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| [design change] NA-14-00003 During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified Dominion Energys claim that aspects of the parameters monitored or inspected and detection of aging effects program elements not associated with the exception identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.
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| In addition, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing a RAI in order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
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| The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.19, Reactor Vessel Material Surveillance Summary of Information in the Application. The SLRA states that AMP B2.19, Reactor Vessel Material Surveillance, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M31, Reactor Vessel Material Surveillance. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will address issues identified but not resolved in this report in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Reactor Vessel Material Surveillance program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020-2322, Subsequent License Renewal Project Aging August 2020 Attachment 1 Management Program Evaluation Report Reactor Vessel Material Surveillance North Anna Power Station NA North Anna Operating Experience Detail Report - Printed Reactor Vessel Material Surveillance 09/05/2019 NA North Anna Operating Experience List Report - Printed Reactor Vessel Material Surveillance 09/05/2019 ETE-SLR-2020-2322, Subsequent License Renewal Project Aging August 2020 Attachment 1 Management Program Evaluation Report Reactor Vessel Material Surveillance North Anna Power Station 1-PT-54 Vessel Irradiation Program Revision 9 2-PT-54 Vessel Irradiation Program Revision 9 ER-AA-RVI-101 Reactor Vessel Integrity Program Revision 6 WCAP-11777 Analysis of Capsule U from the Virginia Electric and 02/1988 Power Company North Anna Unit 1 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12242A089)
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| BAW-1638 Analysis of Capsule V - Virginia Electric & Power 03/1981 Company - North Anna Unit No. 1 - Reactor Vessel Materials Surveillance Program (ADAMS Accession No. ML12242A088)
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| BAW-2356 Analysis of Capsule W - Virginia Power - North Anna 09/1999 Unit No. 1 Nuclear Power Plant (ADAMS Accession No. ML12242A091)
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| WCAP-12497 Analysis of Capsule U from the Virginia Electric and 09/1990 Power Company North Anna Unit 2 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12242A096)
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| BAW-1794 Analysis of Capsule V - Virginia Electric & Power 10/1983 Company - North Anna Unit No. 2 - Reactor Materials Surveillance Program (ADAMS Accession No. ML12242A094)
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| BAW-2376 Analysis of Capsule W - Virginia Power - North Anna 08/2000 Unit 2 Nuclear Power Plant (ADAMS Accession No. ML12298A446)
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| During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP B2.1.19, Reactor Vessel Material Surveillance provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.20, One-Time Inspection Summary of Information in the Application. The SLRA states that AMP B2.1.20, One-Time Inspection, is a new program that, when implemented, will be consistent with the program elements in GALL-SLR Report AMP XI.M32, One-Time Inspection. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the One-Time Inspection program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date Programmatic Work Request for License Renewal CR 120427 11/26/2008 Required RWST Bottom UT Exam CR 1032538 Flanges need replacing on 02-SD-LC-203B 04/01/2016 CR 1046499 Internal Inspection of 01-LO-TK-3 09/07/2016 CR 1078338 While working on 2-ES-45-VALVE found cracks in guide 09/17/2017 CR 1092584 01-SD-348 Pitting on valve body 03/20/2018 CR 375831 Found flange needing to be replaced on 2-CN-EJ-1B 04/09/2010 CR 526080 Valve Seat Damaged 09/15/2013 CR 528241 As-found damage on 01-FW-RO-103A 10/04/2013 Programmatic WOs for license renewal tank CR 546968 04/29/2014 inspection/examinations for Unit 1 IN 2012-19 License Renewal Post-Approval Site Inspection Issues 06/19/2019 North Anna Subsequent License Renewal Project -
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| ETE-SLR-2020-2323 Aging Management Program Evaluation Report - Revision 1 One-Time Inspection ER-AA-NDE-140 NDE Data Processing Revision 6 ER-AA-NDE-200 Mag Particle Exam Revision 8
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| Document Title Revision / Date ER-AA-NDE-300 Liquid Pen Exam Revision 10 ER-AA-NDE-400 Radiographic Exam Revision 2 ER-AA-NDE-801 Ultrasonic Exam of Ferritic Welds Revision 8 ER-AA-NDE-802 Ultrasonic Exam of Austenitic Welds Revision 7 ER-AA-NDE-601 VT-1 Visual Exam Revision 5 ER-AA-NDE-603 VT-3 Visual Exam Revision 7 During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA One-Time Inspection AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP for One-Time Inspection provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.21, Selective Leaching Summary of Information in the Application. The SLRA states that AMP B2.1.21, Selective Leaching, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M33, Selective Leaching. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this audit report in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Selective Leaching program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020-2324 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report -
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| Selective Leaching ETE-NA-2016-0090 Summary of Buried Piping Inspections for North Anna Revision 1 License Renewal Commitment During the audit, the staff verified Dominion Energys claim that the preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| In addition, the staff found that for the scope of program and detection of aging effects program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| The staff reviewed ETE-SLR-2020-2324 and noted visual and mechanical inspection of selected components at both units will be performed for the following environments:
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| CCCW [closed-cycle cooling water] -Chromate, CCCW-Glycol, treated water, raw water, and waste water.
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| The staff reviewed ETE-NA-2016-0090 and noted that examination of a fire protection valve for selective leaching identified a maximum depth of corrosion of 0.129 inches for the internal surfaces and 0.127 inches for the external surface.
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| The staff also audited the description of the SLRA Selective Leaching Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.22, ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The SLRA states that AMP B2.1.22, ASME Code Class 1 Small-Bore Piping, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M35, ASME Code Class 1 Small-Bore Piping. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed the program elements described in the applicants basis documents.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the ASME
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| Code Class 1 Small-Bore Piping program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date License Event Licensee Event Report, North Anna Unit 2 Shutdown Due 06/24/1994 Report (LER) 94- to Reactor Coolant System Leakage Exceeding Technical 005-N2 Specification Limit ICES #237304 Beaver Valley Unit 1, Two Ultrasonic Indications Found in 04/24/2009 Reactor Coolant System Drain Pipe, LER-334-09004-01 CR1144530 Identified Pressure Boundary Leakage on Seal Injection 04/09/2020 Line for 2-RC-P-1A-Pump (Unit 2)
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| CA7902143 The 2-RC-P-1A Thermal Barrier to Seal Injection Line 05/13/2020 Partial Penetration Welded Connection Developed a Crack that Resulted in A RCS Pressure Boundary Leak WO 56203276663 NAPS Unit 2, Ultrasonic Examination Report Fall 2020 Nos. VE-20-003, VE-20-004, and VE-20-005, A Pump Thermal Barrier to Pipe Welds CR 568000 NAPS Unit 1, Reactor Coolant System Leakage Observed 12/23/2014 from B Loop Cold Leg Drain Pipe CR 568193 NAPS Unit 1, Circumferential UT Indication Found in 12/26/2014 Weld 39 on 2 RC-59 CR 576873 Destructive Exams of Unit 1 C Loop Drain Elbow Did Not 04/16/2015 Find Expected Cracking CR 1029889 NAPS Unit 2, Unacceptable UT Indication Found in Weld 02/10/2016 SW-65 A CL Loop Drain RCE001131 Dominion Root Cause Evaluation Through-Wall Leak on 2015 Unit 1 B Reactor Coolant Loop Drain Line Elbow CR 570083 Enhancements Items From RCE001131 01/22/2015 ETE-SLR-2020- Subsequent License Renewal Project Aging Management Revision 1 2325 Program Evaluation Report ASME Code Class 1 Small- 08/2020 Attachment 1 Bore Piping, North Anna Power Station ETE-SLR-2020- Subsequent License Renewal Project Aging Management Revision 1 2325 Program Evaluation Report ASME Code Class 1 Small-Attachment 2 Bore Piping Determination of Populations, North Anna Power Station 59-01-ISI-PLAN- North Anna Power Station Unit 1 Inservice Inspection (ISI) Revision 1 INT-5 Plan for the Fifth Inspection Interval, May 1, 2019 - 08/2019 April 30, 2029 U2 ISI-PLAN 4TH North Anna Power Station Unit 2 ISI-Plan for Components Revision 4 INSP INTERVAL and Component Support for the Fourth Inspection Interval, 07/2019 December 14, 2010 - December 13, 2020 ER-AA-ISI-100 Dominion Inservice Inspection Program Revision 11 ER-NA-AUG-101 North Anna Augmented Inspection Program Revision 10 ER-AA-NDE-140 Dominion Energy Nondestructive Examination Procedure Revision 6 02/20/2020 ER-AA-SPT-100 ASME Section XI System Pressure Test Program Fleet Revision 6 Implementation Requirements ER-AA-NDE-VT-602 VT-2 Visual Examination Revision 6
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| Document Title Revision / Date PI-AA-200 Corrective Action Revision 36 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements in the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
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| The staff verified this description is consistent with the description provided in the GALL-SLR Report and SRP-SLR.
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| SLRA AMP B2.1.23, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The SLRA states that AMP B2.1.23, External Surfaces Monitoring of Mechanical Components, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the External Surfaces Monitoring of Mechanical Components program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date Unisolable leak upstream of 1-SS-TV-111C (Unit 1 C SG CR 387863 07/14/2010 Surface Sample TV)
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| UT readings for Sample System piping from B SG found CR 388050 07/16/2010 below minimum wall thickness Engineering Gap to Excellence - License Renewal CR 569027 01/08/2015 Condition Monitoring CR 1029346 External pipe corrosion on suction line to 2-FW-P-2 03/07/2016 CR 1029351 External pipe corrosion on suction line to 2-FW-P-3A 03/07/2016 CR 1029352 External pipe corrosion on suction line to 2-FW-P-3B 03/07/2016 CR 1085990 2-GM-E-5A Gen H2 Cooler drain line has through-wall leak 12/14/2017 North Anna Subsequent License Renewal Project - Aging ETE-SLR-2020-Management Program Evaluation Report - External Revision 1 2326 Surfaces Monitoring of Mechanical Components
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| Document Title Revision / Date ER-AA-101 System Engineering Walkdowns Revision 3 ER-AA-103 System Engineering Handbook Revision 4 M36 Enhancement Summary No Date During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA External Surfaces Monitoring of Mechanical Components AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit, the staff made the following observation:
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| The staff reviewed the program basis document and noted that the document provides supporting evidence that the inspections performed as part of this AMP have been effective in both detecting and managing aging effects of the external surfaces of mechanical components.
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| The staff also audited the description of the SLRA AMP for External Surfaces Monitoring of Mechanical Components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.24, Flux Thimble Tube Inspection Program Summary of Information in the Application. The SLRA states that AMP B2.1.24, Flux Thimble Tube Inspection, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M37, Flux Thimble Tube Inspection. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Flux Thimble Tube Inspection program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020- Subsequent License Renewal Project Aging 07/2020 2327, Attachment 1 Management Program Evaluation Report Flux Thimble Tube Inspection North Anna Power Station N/A North Anna Operating Experience Detail Report -Flux Printed Thimble Tube Inspection 09/05/2019
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| Document Title Revision / Date N/A North Anna Operating Experience List Report - Flux Printed Thimble Tube Inspection 09/05/2019 ETE-SLR-2020- Subsequent License Renewal Project Aging 07/2020 2327, Attachment 1 Management Program Evaluation Report Flux Thimble Tube Inspection North Anna Power Station 1-PT-210.4 Eddy Current Examination of Incore Detector Thimble Revision 14 Tubes 2-PT-210.4 Eddy Current Examination of Incore Detector Thimble Revision 14 Tubes ER-AA-NDE-501 Eddy Current Examination of Non-Ferromagnetic Tubing Revision 1 ETE-NA-2013-0017 Evaluation of Acceptability of Operation with Unit 2 Revision 0 Incore Thimble Tube N-08 Unisolated ET-N-03-0064 Incore Flux Thimble Eddy Current Test Frequency & Revision 0 Acceptance Criteria Evaluation ET-N-04-0050 Incore Flux Thimble Eddy Current Test Frequency & Revision 0 Acceptance Criteria Evaluation During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP B2.1.24 Flux Thimble Tube Inspection provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The SLRA states that AMP B2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date SW [service water] return header to spray pond CR 1006345 07/22/2015 expansion joints CR 1004375 Sediment and debris found inside 1A2 spray array piping 07/28/2015 CR 1008316 1-WT-PCV-145 sensing line partial blockage 09/01/2015 CR 1010077 MIC [microbiologically influenced corrosion] found in a 09/17/2015 socket weld in line #2-WS-C82-153A-Q3 CR 1050479 Bearing Cooling MIC Leaks 10/13/2016 Develop a Bearing Cooling wall thickness monitoring CA 296112 07/25/2019 plan CR to initiate WR for permanent repair to leak at 2-BC-CR 319405 01/09/2009 TCV-204 Coating and welding repairs required on removed SW CR 1006052 08/12/2015 MEJ 1-BC-PI-111A corrosion and loss of material in pipe CR 1017075 01/04/2015 nipple and union to 1-BC-2 CR 1018242 Bearing Cooling corrosion coupon rack low flow issue 11/13/2015 Weld Build-up Repairs Required on ID of 36.00-WS CR 1021529 12/15/2015 151-Q3 ER-AA-AMP-101 LR Coordinating Activities Revision 11 ER-AA-NDE-VT-601 VT-1 Visual Exam Revision 5 WM-AA-100 Work Management Revision 34 N/A M38 Enhancement Summary No Date ETE-NA-2016-0095 Results of Bearing Cooling Pipe U1 Wall Thickness Insp Revision 1 North Anna Subsequent License Renewal Project - AMP ETE-SLR-2020-2328 Evaluation Report - Inspection of Internal Surfaces in Revision 0 Miscellaneous Piping and Ducting Components During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP for Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.26, Lubricating Oil Analysis Summary of Information in the Application. The SLRA states that AMP B2.1.26, Lubricating Oil Analysis, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M39, Lubricating Oil Analysis. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Lubricating Oil Analysis program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 1033714 2-FW-P-1B Oil Sample 0.05-0.1% Water Concentration 04/12/2016 CR 344088 02-SD-P-2A - Pump Oil sample has small amount of 08/08/2009 water present CR 458489 2-SD-P-1C - Lower motor bearing oil reservoir has small 01/10/2012 amount of water present CR 470292 Request oil sample of 1J EDG Mechanical Governor 04/12/2012 hydraulic oil for particulate CR 543912 2-FW-P Pump oil sample has elevated particulate 04/04/2014 count ETE-SLR-2020-2329 North Anna Subsequent License Renewal Project - Aging Revision 1 Management Program Evaluation Report - Lubricating Oil Analysis ER-AA-PDM-2001 Predictive Maintenance Program Revision 5 ER-NA-AMP-101 Lubricating Oil Analysis Revision 0 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP Lubricating Oil Analysis program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.27, Buried and Underground Piping and Tanks Summary of Information in the Application. The SLRA states that AMP B2.1.27, Buried and Underground Piping and Tanks, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.
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| During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Buried and Underground Piping and Tanks program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR1049897 Leak on Service Water line to U1 Aux Feedwater 10/06/2016 CR498480 Unexpected Backfill Material Found During Buried Pipe 11/29/2012 Program Inspection CR1055877 0-PT-89.9K was Unsat, 2-EG-P-2HB Fuel Oil Line 12/14/2016 Leakage ETE-SLR-2020-2300 North Anna Subsequent License Renewal Project - Revision 2 Aging Management Program Evaluation Report - Buried and Underground Piping and Tanks ER-AA-BPM-101 Underground Piping and Tank Integrity Program Revision 16 ETE-NA-2014-0068 Assessment for Addition of Cathodic Protection to Revision 0 Existing Buried Piping and Tanks at North Anna Power Station Design Change No. Underground Fire Protection Piping Replacement/ North 05/18/2006 04-018 Anna/Units 1&2 ETE-CEP-04-0019 Assessment of External Condition for Buried Piping at Revision 0 Surry and North Anna ETE-NA-2012-0064 Life Cycle Management Plan - Underground Piping and Revision 5 Tank Integrity Program - North Anna Power Station 0-EPM-2303-01 Inspection of Service Water Cathodic Protection System Revision 14 0-EPM-2303-02 Corrosion Survey of Service Water Cathodic Protection Revision 1 System 0-EPM-2303-05 Inspection of Flood Protection Dike Cathodic Protection Revision 5 WO 59102888926 Vendor to Ensure Cathodic Protection of the Buried 09/18/2016 Service Water Piping NAS-271 Field Fabrication and Erection of Piping for North Anna Revision 9 Power Station Units 1&2 NAS-74 Yard Water and Fire Protection Systems for North Anna Revision 4 Power Station
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| Document Title Revision / Date Drawing 11715-FP- Service Water Lines Yard Sheet No. 1 North Anna Power Revision 21 5A Station Drawing 11715-FP- Yard Piping - North Reactor Containment - Sheet 1 - Revision 18 7A North Anna Power Station - Unit 1 Drawing 12050-FP- Yard Piping - North Reactor Containment - Sheet 1 - Revision 17 7A North Anna Power Station Design Change No. Replacement of Buried Fuel Lines - Emergency Diesel 05/09/2017 NA-17-00118 Generator Transfer Pumps to Day Tanks Design Change No. Security Diesel Underground Fuel Oil Storage Tank 10/17/2014 NA-14-00003 Replacement ETE-NA-2016-0090 Summary of Buried Piping Inspections for North Anna Revision 1 License Renewal Commitment Drawing 11715-FV- Underground Fuel Oil Storage Tanks I-EG-TK-2A & 2B Revision 8 46A-8 The staff found that for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| The staff reviewed ETE-SLR-2020-2300 and noted the following: (a) buried copper piping is included within the scope of the program; (b) buried stainless steel piping may be coated, wrapped, or tape-wrapped; (c) stainless steel piping is not required to be coated based on chloride index value of zero for each of the 24 soil sample locations throughout NAPS; (d) buried steel piping may be coated with coal tar epoxy, coal tar enamel, coal tar epoxy encased in concrete; or tape wrap; and (e) acceptable applied coatings for underground steel and copper alloy piping are coal tar enamel, coal tar epoxy, unidentified material, and none.
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| The staff reviewed CR 1049897 and noted the following: (a) the buried leak was caused by external corrosion; and (b) the investigation into the cause of corrosion identified that the piping was not coated and wrapped in accordance with the installation specification.
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| The staff reviewed 0-EPM-2303-01 and noted that the acceptance range for instant-off potentials includes a limiting critical potential of -1,500 miliVolt (mV).
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| The staff review WO 59102888926 and noted that there was one section of subsystem B when the -1.200-volt value had been exceeded and hydrogen could be liberating.
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| The staff reviewed CR 498480 and noted the following: (a) unexpected backfill material was found against the surfaces of fire protection piping; (b) backfill material contains gravel above the size of Virginia Department of Transportation Grade B granular fill material specified for the fire protection replacement project (NAI-0034); (c) the original fire protection installation specification (NAS-0074) does not identify a maximum backfill material size; and (d) a formal Buried Pipe Program inspection was completed, and the external pipe coating was found not to be damaged.
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| The staff reviewed NAS-74 and noted that buried fire protection piping is cast iron with a cement mortar lining and bituminous coating.
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| The staff reviewed Design Change No. 04-018 and noted the following: (a) buried cast iron fire main pipe ruptures have occurred at pre-existing flaws that have grown as a result of low cycle fatigue from periodic system pump pressure testing; and (b) buried ductile iron fire protection lines are coated with an asphaltic exterior coating.
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| The staff reviewed Drawing 11715-FV-46A-8 and noted buried fuel oil storage tanks are (a) internally coated with a minimum of 3 mils of Carbozinc 11 or equal; and (b) externally coated with a minimum of 16 mils of Koppers Bitumastic 300-M or equal.
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| The staff also audited the description of the SLRA Buried and Underground Piping and Tanks program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Summary of Information in the Application. The SLRA states that AMP B2.1.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, is an existing program with an exception and enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, as modified by ISG SLR-ISG-Mechanical-2020-XX, Updated Aging Management Criteria for Mechanical Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.
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| During the audit, the staff reviewed the exceptions and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 1029885 Three Ultrasonic Testing Data Points for Unit 2 03/10/2016 Emergency Condensate Storage Tank Found Below Minimum Wall Thickness
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| Document Title Revision / Date CR 567522 Weld Build-up Required on Inner Diameter of Service 12/16/2014 Water Header CR 1010434 Weld Build-up Repair Required on Inner Diameter of 09/22/2015 Service Water Header CR 343843 Results of Coating Inspection of 1-CC [Component 08/05/2009 Cooling]-E-1A Channel Head Interior CR 567616 Minor Coating Defects in the A Service Water Header 12/16/2014 CR 1072375 Documentation of Weld Repairs in B Service Water 06/27/2017 Header CR 1101212 Coating Repairs Required on Inner Diameter of Service 07/10/2018 Water Piping ETE-SLR-2020-2331 North Anna Subsequent License Renewal Project - Revision 2 Aging Management Program Evaluation Report -
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| Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks CM-AA-CTG-104 Condition Assessment of Internally Coated/Lined Tanks, Revision 3 Components, and Pipes Subject to Immersion Service ER-NA-INS-104 Monitoring of Structures North Anna Power Station Revision 10 During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| The staff also verified Dominion Energys claim that aspects of the detection of aging effects and corrective actions program elements not associated with the exception identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.
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| In addition, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing a RAI in order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER. The staff will consider issuing a RAI in order to obtain the information necessary to determine whether Dominion Energys SLRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program can be adequate to manage the associated aging effects.
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| The staff also audited the description of the SLRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program provided in the UFSAR supplement.
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| The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.29, ASME Section XI, Subsection IWE Summary of Information in the Application. The SLRA states that AMP B2.1.29, ASME Section XI, Subsection IWE, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S1, ASME Section XI, Subsection IWE. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the ASME Section XI, Subsection IWE program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date N/A North Anna Operating Experience List Report - ASME Printed Section XI, Subsection IWE 07/07/2020 N/A North Anna Operating Experience Detail Report - ASME Printed Section XI, Subsection IWE 07/07/2020 DC 99-160 Repair Through-Wall Defect in Containment Liner, North 09/24/1999 Anna Unit 2 MAT-99-0003 Containment Liner and Coating Evaluation, North Anna 09/30/1999 Unit 2 CR 1117899 ASME Section XI General Visual Inspection of 03/11/2019 Containment Liner in the Keyway below Incore Instrumentation Area CR 1029653 Bulging and Staining on Unit 2 Containment Liner at 03/09/2016 Electrical Penetration Area CA 7563943 Document Evaluation of IWE Inspection Results 04/08/2019 VT-19-077 Visual Examination of IWE Surfaces (General - Moisture 04/24/2019 Barriers), North Anna Unit 2 PIR 1112472 NANN and MPS to perform an effectiveness review of all Printed Initial License Renewal AMAs/AMPs 12/02/2019 ETE-SLR-2020-2334 Attachment 1: North Anna Subsequent License Renewal Revision 0 Project - Aging Management Program Evaluation Report
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| - ASME Section XI, Subsection IWE, and Attachment 2:
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| Summary of Fatigue Waiver - Pressure Retaining Components Subject to Cyclic Loading, But Have No CLB [current licensing basis] Fatigue Analysis NAPS CONT IWE NAPS Unit 1 / 2 Containment IWE Inservice Inspection Revision 0 PLAN Plan -Third Ten-Year Containment Plan NAPS Containment Revision 1 Revision 1 ISI Basis (PROC59)
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| U1-3rd-TEN-YR- NAPS Unit 1 3rd Ten-Year Containment ISI Interval Revision 1 CONT-IWE/IWL IWE/IWL Implementation Schedule U2-3rd-TEN-YR- NAPS Unit 2 3rd Ten-Year Containment ISI Interval Revision 1 CONT-IWE/IWL IWE/IWL Implementation Schedule
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| Document Title Revision / Date ER-AA-CII-102 ASME Section XI CISI (Metal/IWE) Program Fleet Revision 3 Implementation Requirements ER-AA-NDE-VT-605 IWE Visual Examination Procedure (Nuclear Fleet Revision 2 Procedure)
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| NAS-41 Specification for Shop Fabrication and Field Erection of Revision 2 Reactor Containment Liner Plate for NAPS NAS-21 Specification for Reactor Containment Electrical Revision 3 Penetrations for NAPS NAS-2094/NUS- General Procurement Specification for Pressure Revision 6 2206 Boundary Threaded Fasteners (Nuclear Fleet Procurement Specification) 0-MCM-1006-07 Removal, Inspection and Installation of Safety-Related Revision 3 Blind Flanges (Mechanical Corrective Maintenance Procedure) 0-GEP-18 Torque Selection Guidance (NAPS General Engineering Revision 2 Procedure)
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| Drawing ISI Containment Liner - Mat Liner Segment Location Revision 0 11715/12050-IWE- Schedule, NAPS Unit 1/Unit 2 M001 Drawing ISI Containment Basement Liner Test Connections, Revision 1 11715/12050-IWE- NAPS Unit 1 / Unit 2 M002 Drawing ISI Containment Basement Liner Test Port Panels Revision 1 11715/12050-IWE- Arrangement, NAPS Unit 1 / Unit 2 M003 ER-AA-RRM-100 ASME Section XI Repair/Replacement Program Fleet Revision 7 Implementation Requirements ETE-MAT/99-0003 Containment Liner and Coating Evaluation, NAPS Unit 2 Revision 0 09/30/1999 ETE-SLR-2020-2333 NAPS SLR Project: Aging Management Program Revision 1 Evaluation Report - Operating Experience for AMPs PA 7503472_PIR 11 Aging Management Effectiveness Review - ISI No Date 12472 Containment UFSAR Section 18.2.12 CR 1095927 Contingency Work Order to Repair CTMT [containment] 04/28/2019 Liner Coatings Under Vessel - Unit 2 CR 1119578 Coating Repairs Identified in Unit 2 Keyway (Follow-on 03/30/2019 from CR 1117899)
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| WO 59203144652 Contingency Work Order to Repair CTMT Liner Coatings 04/06/2019 Under Vessel (Incore Instrumentation Area) - Unit 2 (59102859373)
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| WO 59102859373 Containment Visual Exam / Keyway / ER-AA-CII-102 / 04/04/2019 After Panel Removal, Unit 2 WO 59103057002 Visual Examination of Interfaces N1R26 Outage - NAPS 04/2018 Unit 1 (ISI IWE pages 1026-1044)
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| WO 59203136641 Visual Examination of Interfaces N2R26 Outage - NAPS 04/2019 Unit 2 (ISI IWE pages 785-837)
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| In addition, the following documents were identified by the staff and requested to be made available to the staff via the ePortal.
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| : 1) In CR 574846 regarding OpE4, provide the referenced WO 59102846862 to closure.
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| : 2) In CR 1029653 regarding OpE6, provide the referenced WO 59102944960 to closure and engineering evaluation performed for bulge.
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| : 3) Provide CR 1094362 and CR 1094363.
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| : 4) Provide CR 373299 and design change package (DCP) NA-09-00133 with pictures of degraded test channel connection plugs
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| : 5) Provide drawings of containment floor leak chase channels and test connections (e.g., Drawing 11715/12050-IWE-M001/M002/M003)
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| : 6) CR 416069 - provide the resolution of the identified issue with pitting of equipment hatch door
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| : 7) Provide the pictures associated with CR 1091793 and CR 1093173
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| : 8) Provide CR 1095927 and WO 59102859373 to closure associated with containment liner degradation in Key Way below Incore Instrumentation Area. Also, provide related CR 1119578 and WO 59203286867.
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| : 9) With reference to CR 1029261, provide pictures of basemat-liner inspection referred to in the long description.
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| : 10) With reference to PIR 1112472 (OpE11), provide results of effectiveness review performed with regard ISI and augmented examinations specifically related to ASME Section XI, Subsection IWE AMP.
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| During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, monitoring and trending (consistent with enhancement) and corrective actions program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements that were also associated with enhancements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will use a voluntary SLRA supplement agreed to by Dominion Energy during the audit or consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP ASME Section XI, Subsection IWE provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP ASME Section XI, Subsection IWE. The staff will use a voluntary SLRA supplement agreed to by Dominion Energy during the audit or consider issuing a RAI in
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| order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
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| SLRA AMP B2.1.30, ASME Section XI, Subsection IWL Summary of Information in the Application. The SLRA states that AMP B2.1.30, ASME Section XI, Subsection IWL, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.S2, ASME Section XI, Subsection IWL. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the ASME Section XI, Subsection IWL program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date N/A North Anna Operating Experience List Report - ASME 09/18/2020 Section XI, Subsection IWL N/A North Anna Operating Experience Detail Report - ASME 09/18/2020 Section XI, Subsection IWL CR 1031939 Suspect area found during containment IWL inspection 03/27/2016 CR 1040128 Two holes noted during Unit 1 IWL concrete inspection 06/16/2016 CR 1043062 Embedded wood found on the shell during containment 07/25/2016 IWL concrete inspection CR 472650 Safety-related work order review follow-on item 04/27/2012 CR 441424 Work order needed for Unit 1 containment code concrete 09/04/2011 repair CR 435773 Concrete defect found during Unit 2 containment 07/27/2011 concrete inspection CR 436777 Work order requested to repair U1 containment concrete 08/04/2011 NAPS CONT IWL NAPS Containment IWL Inservice Inspection Plan Third Revision 0 PLAN Ten-Year Containment Plan 03/14/2017 ETE-SLR-2020-2335 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report - ASME Section XI, Subsection IWL ER-AA-CII-101 ASME Section XI Containment Inservice Inspection Revision 4 (Concrete/IWL) Program Fleet Implementation Requirements ET-CCE 02-0001 ASME Section XI, Subsection IWL - Containment 02/27/2002 Concrete Examination and Evaluation Report - North Anna Power Station, Unit 1 and 2 ETE-NA-2016-0069 Unit 1 Containment IWL Inspection Report and Revision 0 Evaluation ETA-NA-2016-0072 Unit 2 Containment IWL Inspection Report and Revision 0 Evaluation
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| The following documents were identified by the staff and requested to be made available to the staff on the ePortal. Unless otherwise noted, these documents were reviewed and discussed with the applicant during the audit and the issues were resolved. Any unresolved issues will be evaluated in the SER.
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| : 1) CR 1031939 mentions a suspect area that is 12 x 36 and has cracks and efflorescence. Provide documentation showing how this issue was resolved.
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| : 2) CR 1040128 mentions two holes in the concrete but does not quantify the holes.
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| Provide documentation explaining the extent of the degradation and the resolution.
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| : 3) Multiple CRs from the Unit 2 2016 ASME Section XI inspection note that excavation is required to determine extent of concrete degradation. These are generally closed to existing WO 59102986415. Provide documentation demonstrating how these items were resolved, especially CR 1043062 and CR 1043057 (embedded wood) and CR 1043058 (exposed rebar).
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| : 4) CR 472650 discusses a crack in containment and discusses limitations on loads on the containment due to the crack. Closure of CR discusses CA 233394 and CA 233395 for long-term repairs. Provide more information about this crack and how the issue was ultimately addressed.
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| : 5) CR 441424 discusses degradation that resulted in a code repair. Provide documentation that demonstrates how this code repair was completed (possibly captured in WO 59102350254).
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| : 6) CR 435773 mentions a popout that needs to be repaired to prevent future degradation to reinforcement; however, no additional actions are discussed. Provide documentation of the resolution of this issue.
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| : 7) CR 436777 mentions an area with multiple popouts to the left of the equipment hatch.
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| Provide information on how this issue was resolved.
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| During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA ASME Section XI, Subsection IWL provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report Table XI-01.
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| SLRA AMP B2.1.31, ASME Section XI, Subsection IWF Summary of Information in the Application. The SLRA states that AMP B2.1.31, ASME Section XI, Subsection IWF, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S3, ASME Section XI,
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| Subsection IWF. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the ASME Section XI, Subsection IWF program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date NAPS XI.S03 ASME Section XI, Subsection IWF Summary of Detailed 10/01/2019 OpE Evaluations CR 395483 2 (HILTI-KWIK-BOLT) anchor bolt nuts on top of base plate 09/20/2010 do not seat tightly to base plate (as described in Structures Monitoring OpE evaluations)
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| CR 364805 NRC identified condition at discharge piping supports, 01/11/2010 1-FW-P-3B (Appendix B OpE example 2, outline augmented in NAPS XI.S03 to include additional CRs)
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| WO 59102052185 Install shim to close gap on (U1) 1-FW-P3B discharge 03/12/2010 piping and seismic supports, (Appendix B OpE Summary Example 2, augmented reference CR 364805 in NAPS XI.S03 includes similar WOs for several U1 AFW [auxiliary feedwater] pipe supports)
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| WO 59102064646 Install shim to close gap on (U2) 2-FW-P-3A discharge 03/15/2010 piping and seismic supports (Appendix B OpE Summary Example 2, augmented reference CR 364805 in NAPS XI.S03 includes similar WOs for several U2 AFW pipe supports)
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| WO 59102359300 VT-3 Exam of pipe hanger. Tighten loose spring hanger 10/05/2011 (U1) riser clamp bolt (Appendix B OpE Summary Examples 3 10/08/2011 WO 59102348335 and 4, referenced (U1) CR443144 and (U2) CR 446060 in (U2) XI.S03)
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| CR 470579 VT-3 Exam (U1), excessive corrosion on pipe clamp 04/13/2012 (Appendix B OpE Summary Example 6)
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| CR 374781 Bent bolt (U2). Lack of nut thread engagement (outline in 04/01/2010 NAPS XI.S03)
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| CR 513903 Preservice VT-3 exam found improper thread engagement 05/01/2013 on support arm base plate to I-beam for SH-32 (outline in NAPS XI.S03 for unknown unit, references WO 59102603286)
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| CR 448934 NDE Exams of Rx vessel, U1 sliding foot (see also 10/20/2011 FE [Further Evaluation] 3.5.2.2.2.6 Audit Report remarks)
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| CA 216824 VT-1 and NDE examination results, U1 sliding foot 10/25/2011 WO 59102362906 ISI/NDE, VT-3 exams during U1 forced outage, U1 sliding 03/07/2012 foot (procedure ER-AA-NDE-VT-603)
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| CR 448737 VT-3 inspection of U2 Rx vessel Hot Leg sliding foot, rub 10/19/2011 marks identified on sliding foot vertical face component (see also FE 3.5.2.2.2.6 Audit Report remarks)
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| WO 59102346793 ISI/NDE, VT-3 for back side of U2 sliding support 02/08/2012 (procedure ER-AA-NDE-VT-603)
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| Document Title Revision / Date ETE-SLR-2020-2336 NAPS SLR Project, AMP Evaluation Report ASME Revision 1 Section XI, Subsection IWF 59-01 ISI-PLAN-INT- VEPCO-NAPS U1 I5-ISI-Plan (AMP B2.131, ASME Draft Revision 1 5 Section XI, Subsection IWF, Enhancement 1)
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| U2 ISI-PLAN-4th VEPCO-NAPS U2 I4-ISI-Plan (AMP B2.131, ASME Draft Revision 3 INSP INT Section XI, Subsection IWF, Enhancement 1)
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| ER-NA-AUG-101 NAPS Augmented Inspection Program (AMP B2.131, Draft Revision ASME Section XI, Subsection IWF, Enhancements 2, 3, 11 and 4)
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| MS-AAWHS-131 Storage and handling Revision 12 ER-AA-NDE-VT-603 VT-3 Visual Examination Procedure Revision 0 ETE-SLR-2020-2418 NAPS SLRA - Position Paper - Lubrite Aging Effects Due Revision 0 to Radiation (see also FE 3.5.2.2.2.6 Audit Report remarks)
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| ETE-SLR-2020-2603 NAPS SLRA - FE Recommendation Report - SRP Section Revision 1 3.5 - Containment, Structures, and Component Supports GMP-C-108 NSS [nuclear steam system] NAPS U1 and U2 Work Revision 2 Procedure - Structural and Miscellaneous Steel N/A NANN/SURR High-Strength Structural Fasteners (A325 08/17/2020 and A490) - Report for SLR Team N/A Unbrako Engineering Guide No Date CM-AA-DDC-201 Fuel Oil Pump House High Pressure CO2 Fire protection 08/27/2015 System Replacement (Attachments 3 and 4) - DC:
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| NA-12-00106 HILTI Catalog - HILTI Anchoring Solutions for the Nuclear Industry 12/03/2020 App B NAS-1023/NUS- Specification for Installation of HILTI-KWIK-Bolt II and Revision 2 3007 HILTI-KWIK-Bolt 3 Anchor Bolts - North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2 NAS-3018/NUS- Specification for Installation of DRILLCO MAXI BOLT Revision 0 2028 Anchor Bolts - North Anna and Surry Power Stations CE-0027 Technical Report: HILTI-KWIK-BOLT II (HKB II) - North Revision 1 Anna Power Station Units 1 & 2 CE-0319 Technical Report: HILTI-KWIK-BOLT 3 (KB 3) Expansion Revision 0 Anchors - North Anna and Surry Power Stations Units 1 & 2 Drawing 11715-FV- Drawing - Pressurizer Support, SH4 Revision 4 19D Drawing 11715- Inservice Inspection Detail Drawing, Steam Generator: Revision 5 WMKS-RC-E-1A.1 1-RC-E-1A, NAPS Unit1 Virginia Power (Lubrite)
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| Drawing 11715-FV- Drawing - Reactor NST, NAPS (Sliding Foot) Revision 5 6D-6 Drawing 11715-FV- Drawing - RCP Support Assembly Revision 5 20A-8 Drawing 12050-FV- Drawing - ST. GEN. Lower Support Foot Attachment Revision 1 17G Details, NAPS U2 Drawing 12050-FV Drawing - Pressurizer Support SH4, NAPS U2 Revision 2 19D
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| During the audit, the staff verified that the program elements that Dominion Energy declared were consistent or would be consistent after enhancements, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| The staff reviewed DRAFT revisions of U1, 59-01 ISI-PLAN-INT-5, U2, ISI-PLAN-4th INSP INT, and ER-NA-AUG-101, and verified pending activities (e.g., revise procedures, augment inspection manual) to support implementation of enhancements to ASME Section XI, Subsection IWF AMP as noted in SLRA Table A4.0-1, Subsequent License Renewal Commitments.
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| The staff reviewed HILTI Catalog - App B and confirmed that Dominion Energy post-installed HILTI anchor bolts meet the requirements of NQA-1 2000 and 10 CFR Appendix B.
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| The staff also reviewed Technical Reports CE-0027 and CE-0319 and confirmed, based in part on performed on-site tests, the HKB II and KB3 post-installed anchors are adequate to support the applied loads and loading conditions for different concrete mixtures used at NAPS.
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| The staff reviewed NANN/SURR High Strength Structural Fasteners (A325 and A490) -
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| Report for SLR Team, GMP-C-108, and MS-AA-WHS-131 and confirmed that NAPS follows Research Council on Structural Connections Specifications for structural joints using High-Strength bolts and no molybdenum disulfide lubricants are used on structural bolting.
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| The staff reviewed CM-AA-DDC-201, Fuel Oil Pump House High Pressure CO2 Fire protection System Replacement (Attachments 3 and 4) - DC: NA-12-00106 and confirmed that adhesive anchors have been used in temporary constructs within the plant but are not used on permanent IWF supports.
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| The staff also audited the description of the SLRA AMP B2.1.31, ASME Section XI, Subsection IWF provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report Table XI-01.
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| SLRA AMP B2.1.32, 10 CFR Part 50, Appendix J Summary of Information in the Application. The SLRA states that AMP B2.1.32, 10 CFR Part 50, Appendix J, is an existing performance monitoring program that is consistent with the program elements in GALL-SLR Report AMP XI.S4, 10 CFR Part 50, Appendix J. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the 10 CFR Part 50, Appendix J program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date N/A Historical Type A Test Data (Includes Type A Test Interval 09/17/2020 Extension - LAR [license amendment request] request dated 06/30/2014)
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| N/A NAPS Appendix J OpE Detail Report 05/23/2019 CR 325923 Unit 1, Containment Liner to Equipment Hatch Leakage 03/08/2009 WO 59101879366 Unit 1, Inspect Gasket Grooves on Equipment Hatch 03/30/2009 CR 441423 Unit 1, Leakage during 1-PT-61.2.3.1 09/04/2011 CR 399655 Unit 1, Surface Pitting on equipment hatch door near seal 10/19/2010 surfaces ETE-SLR-2020-2337 NAPS SLR Project, AMP Evaluation Report - 10 CFR Part 50, Revision 1 Appendix J ER-NA-APJ-318 10 CFR 50 Appendix J Program (Containment Leakage) Revision 4 ER-AA-CII-101 ASME Section XI Containment ISI (Concrete/IWL), Fleet Revision 4 ER-AA-CII-102 ASME Section XI Containment ISI (Concrete/IWE), Fleet Revision 3 1-PT-61.3.4 Total Leak Rate Calculation Revision 13 2-PT-61.3.4 Total Leak Rate Calculation Revision 15 1-PT-61.1 NAPS Reactor Containment ILRT [integrated leak rate test] Revision 29 1-PT-61.1 OTO PAR NAPS Reactor Containment ILRT, includes NAPS U1 2007 Revision 20 ILRT complete documentation (10/04/2014) 2-PT-61.1 NAPS Reactor Containment ILRT Revision 27 2-PT-61.1 OTO PAR NAPS Reactor Containment ILRT, includes NAPS U2 2014 Revision 25 ILRT complete documentation (10/10/2007) 1-PT-61-3 Containment Type C Test Revision 42 2-PT-61-3 Containment Type C Test Revision 50 1-PT-61.2.1A Containment Type B Testing - Electrical Penetrations, Row 1, Revision 3 Penetrations 1A-1E (Typical for all electrical penetrations through Row 24) 2-PT-61.2.2A Containment Type B Testing - Electrical Penetrations, Revision 3 Penetrations 1A-1E (Typical for all electrical penetrations through Row 24) 1-PT-61.2.3 Containment Type B Test - Equipment Hatch Revision 15 2-PT-61.2.3 Containment Type B Test - Equipment Hatch Revision 17 1-PT-61.1A Containment Structural Inspection Revision 17
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| Document Title Revision / Date 2-PT-61.1A Containment Structural Inspection Revision 14 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| The staff reviewed 10 CFR Part 50, Appendix J testing procedures for Units 1 and 2. The units have separate procedures, even though they have the same tasks. This is because the timing of the testing is based on the units licensing date and therefore differs between the units.
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| The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.
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| The staff verified this description is consistent with the description provided in the GALL-SLR Report Table XI-01.
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| SLRA AMP B2.1.33 Masonry Walls Summary of Information in the Application. The SLRA states that AMP B2.1.33, Masonry Walls, is an existing condition monitoring program that is consistent with the program elements in GALL-SLR Report AMP XI.S5, Masonry Walls. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will document its review of the SLRA AMP in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Masonry Walls program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED
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| -Document Title Revision / Date N/A North Anna Operating Experience List Report - Masonry Printed Walls 08/13/2019 N/A North Anna Operating Experience Detail Report - Printed Masonry Walls 08/14/2019 CR 328048 Crack in turbine building wall 03/23/2009 CR 439771 Cracks in block north wall of service building locker room 08/27/2011 CR 439806 Crack in wall 08/27/2011 CR 441493 Vertical and horizontal crack on north wall of the service 09/05/2011 building
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| -Document Title Revision / Date CR 442366 Crack in block wall SB-294-3 (East wall of MER #2) 09/10/2011 PIR 1112472 Performance Improvement Detail Report Printed 07/09/2020 PA 7469824-NANN Effective review of the initial license renewal AMAs/AMPs Printed Rev 07/09/2020 ETE-SLR-2020-2338 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report -
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| Masonry Walls ER-NA-INS-104 Monitoring of Structures North Anna Power Station Revision 10 CCE-97-0011 Maintenance Rule Condition Assessment of Plant Revision 0 Structures Evaluation of Deviation Reports North Anna Power Station Units 1 and 2 ETE-NA-2015-0020 Condition Assessment of Plant Structures (Third Five- Revision 0 Year Inspection Interval)
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| ET-N-07-0120 Monitoring of Structures - Report of 5 Year Periodic Revision 0 Inspections N02-073 Monitoring of Structures - Report of 5-Year Periodic Revision 0 Inspections North Anna Power Station Units 1 & 2 NA-CAL-CIV- Block Wall Review IE 80-11 Printed 13075.63-AB-259-2 08/13/2015 NA-CALC-ZZZ- Block Wall Review IE 80-11 Printed 13075.63-5C-10 07/28/2017 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Masonry Walls program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report, Table XI-01.
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| SLRA AMP B2.1.34, Structures Monitoring Summary of Information in the Application. The SLRA states that AMP B2.1.34, Structures Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S6, Structures Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table
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| below lists documents that were reviewed by the staff and were found relevant to the Structures Monitoring program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020-2339 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report -
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| Structures Monitoring ER-NA-INS-104 Monitoring of Structures North Anna Power Station Revision 10 NAPS UFSAR North Anna Power Station Updated Final Safety Analysis Revision 55.02 Report MS-AA-WHS-131 Storage and Handling Revision 12 GMP-C-108 Structural and Miscellaneous Steel Revision 2 0-PT-112.1 Groundwater Testing Revision 4 NAS-0181 Specification for Structural Steel for North Anna Power 08/24/1970 Station ET-CCE-97-0011 Maintenance Rule Condition Assessment of Plant Revision 0 Structures Evaluation of Deviation Reports North Anna Power Stations Units 1 & 2 ET N-07-0120 Monitoring of Structures - Report of 5-Year Periodic Revision 0 Inspections ETE-NA-2015-0020 Condition Assessment of Plant Structures (Third Revision 0 Five-Year Inspection Interval) 1-PT-9.3 Erosion Control inspection - Station Site Revision 14 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| In addition, the staff found that for the parameters monitored or inspected program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing an RAI in order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| The staff reviewed ER-NA-INS-104, Monitoring of Structures North Anna Power Station, and confirmed that the valve body component listed in SLRA Table 3.5.2-15 as being managed for loss of material by the Structuring Monitoring Program is the same
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| component that is referenced as steel culvert in Attachment 6 of ER-NA-INS-104, List of Earthen Structures.
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| The staff reviewed SLRA Table 3.5.2-38, Structures and Component Supports -
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| Component Supports - Aging Management Evaluation, and confirmed that the listed spring hanger component is being added as a new component within the scope of the Structure Monitoring Program under components support members, as specified in Enhancement 2.
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| The staff also audited the description of the SLRA Structures Monitoring Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.35 Inspection of Water-Control Structures Associated With Nuclear Power Plants Summary of Information in the Application. The SLRA states that AMP B2.1.35, Inspection of Water-Control Structures associated with Nuclear Power Plants, is an existing condition monitoring program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S7, Inspection of Water-Control Structures associated with Nuclear Power Plants. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Inspection of Water-Control Structures associated with Nuclear Power Plants program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date N/A North Anna Operating Experience List Report - Printed Inspection of Water-Control Structures Associated with 11/15/2019 Nuclear Power Plants N/A North Anna Operating Experience Detail Report - Printed Inspection of Water-Control Structures Associated with 11/15/2019 Nuclear Power Plants CR 441425 Crack on discharge tunnel 09/04/2011 CR 442163 Unit Circulating Water Tunnel cracks 09/09/2011 CR 428000 Vegetation needs to be cut-back or sprayed with 05/20/2011 herbicide at the SW reservoir CR 509391 Additional concrete degradation found at service water 03/27/2013 pump house CR 546978 Vegetation growing on the inside bank of the Service 04/29/2014 Water Reservoir CR 1038564 NOD Audit Finding 16-04-01NS: Administrative Control 05/26/2016 not effective for License Renewal Program PIR 1060484 Formal SA - License Renewal Implementation at North Printed Anna Power Station (Phase II NRC Inspection) 09/01/2020
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| Document Title Revision / Date PIP 1011181 Perform an informal self-assessment on license renewal Printed 07/23/2019 PA 7469824 NANN to Perform an Effectiveness Review of their Initial Printed License Renewal AMAs/AMPs 07/09/2020 PA 7503447 Perform Aging Management Program effectiveness Printed review for Civil Inspections 08/08/2019 CCE-97-0011 Maintenance Rule Condition Assessment of Plant Revision 0 Structures Evaluation of Deviation Reports North Anna Power Station Units 1 & 2 ETE-NA-2015-0020 Condition Assessment of Plant Structures (Third Revision 0 Five-Year Inspection Interval)
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| ET-N-07-0120 Monitoring of Structures - Report of 5-Year Periodic Revision 0 Inspections N02-073 Monitoring of Structures - Report of 5-Year Periodic Revision 0 Inspections North Anna Power Station, Units 1 & 2 0-PT-75.12 Visual Inspection of the Service Water Reservoir Dike Revisions 6 Crest and Toe and 7 ETE-SLR-2020-2340 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report -
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| Inspection of Water-Control Structures associated with Nuclear Power Station 0-PT-112.1 Groundwater Test Revision 4 1-PT-9.2 Service Water Reservoir ISI Revision 5 ER-NA-INS-104 Monitoring of Structures North Anna Power Station Revision 10 GMP-C-108 Structural and Miscellaneous Steel Revision 2 GMP-M-150 Fabrication and Installation of Safety- Revision 17 Related/Seismic/Fire Protection Supports and Structures MS-AA-WHS-131 Storage and Handling Revision 12 0-PT-75.6.2 Horiz Drains Flow Rate - Clarity Revision 10 CALC ME-0200 Re-evaluation of 0-PT-75.22 Test Interval Revision 0 ETE-NA-2016-0084 License Renewal Commitment #23: Measure Sludge Revision 1 Build-up in the SW Reservoir 0-PT-75.22 Service Water Reservoir Sludge Depth Measurement Revision 7 During the audit, the staff verified that the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Inspection of Water-Control Structures associated with Nuclear Power Plants, program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report, Table XI-01.
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| SLRA AMP B2.1.36, Protective Coating Monitoring and Maintenance Summary of Information in the Application. The SLRA states that AMP B2.1.36, Protective Coating Monitoring and Maintenance, is an existing program that is consistent with NUREG-2191, Section XI.S8, Protective Coating Monitoring and Maintenance as modified by SLR-ISG-Structures-2020-XX, Updated Aging Management Criteria for Structures Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the program.
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| The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 326205 Results of Engineering Containment Walkdown - 03/10/2009 Annulus and Basement CR 373761 Results of Containment Walkdown - Cubicles and Loop 03/25/2010 Room CR 1033229 Coatings Blister Removed from Containment Conduit 04/08/2016 Box10-C CR 1091793 Areas for Coating Repair Along U1 Containment Liner to 03/12/2018 Basement Interface ETE-SLR-2020-2341 North Anna Subsequent License Renewal Project - Aging Revision 2 Management Program Evaluation Report - Protective Coating Maintenance and Monitoring CM-AA-CRS-103 Containment Condition Assessment, Nuclear Fleet Revision 5 Technical Procedures, Dominion CM-AA-CRS-10 Coating Program, Nuclear Fleet Program Description, Revision 5 Dominion During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP Protective Coating Monitoring and Maintenance program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program with enhancements, that will be consistent with the program elements in GALL-SLR Report AMP XI.E1, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed the program elements described in the applicants basis document as well as the available current relevant maintenance procedures.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 1029285 2-MH-CRN-1 has deteriorated cable with conductors 05/07/2019 showing CR 1035531 Extent of condition for B RSST [reserve station service 07/17/2019 transformer] cable jacket CR 1061681 Found cable outer jacket cracked/degraded exposing 07/16/2019 copper shielding CR 107740 Damaged cables at U2 containment penetrations 01/31/2019 CR 1078115 Work order request for cable testing/repairs 01/31/2019 (2-CC-TE-272)
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| ETE-SLR-2020-2343 North Anna Subsequent License Renewal Project - Revision 1 Aging Management Program Evaluation Report -
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| Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ER-AA-CBL-101 Evaluation and Testing of Low-Voltage Cables Revision 3 ER-AA-CBL-103 Evaluation and Testing of Medium-Voltage Cables Revision 3 ETE-SLR-2020-2408 North Anna Subsequent License Renewal Project - Revision 0 Position Paper - Electrical Cables and Connections Insulation Types During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects,
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| monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| During the teleconference call with Dominion Energy on October 22, 2020, the staff noted that there are two cables at NAPS that have fire retardant coating. Visual inspection of cables in adverse localized environment that have fire retardant coating may not be adequate because the insulation material would not be visible. The staff requested Dominion Energy to clarify inspection techniques for material conditions of cables covered with fire retardant. In the teleconference call on January 4, 2020, Dominion Energy clarified that these two feeder cables (for charging pump and CC water pump) have retardant fire wrap only on a portion of the cable run. Additionally, these cables have metallic armor sheathing due to their design requirements, which obscures the cable insulation system. The licensee verified that these cables are not in adverse localized environment. The staff finds that since these cables are not installed in an adverse localized environment, they are not in-scope of AMP B2.1.37.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Summary of Information in the Application. The SLRA states that AMP B2.1.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, is an existing program that, following enhancements, will be consistent with the program elements in GALL-SLR Report AMP XI.E2, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed the program elements described in the applicants basis document as well as the available supporting documents.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR1038128 2-SW-RM-225 Indication failed low 03/13/2019
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| Document Title Revision / Date CR1055979 Broke wire in high volts box of 2-RM-RMS-259 detector 07/11/2019 CR326320 Failed Conax connector found on P1 cable for 01-NM- 07/11/2019 NFD-190 CR363024 Work order needed to replace 2-NI-CHA-N-43A cable 07/17/2019 and drawer connector CR 442248 Unit 1 N36, Intermediate Range Channel 2, indication is 07/15/2019 higher than expected ETE-SLR-2020-2344 North Anna Subsequent License Renewal Project - Revision 2 Aging Management Program Evaluation Report-Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits 1-ICP-NI-N-31 NIS Source Range Channel I (N-31) Calibration Revision 20 Markup I-ICP-NI-N-32 NIS Source Range Channel II (N-32) Calibration Revision 20 Markup ICP-RM-2-RMS-265 Containment High Range Radiation Monitoring System Revision 23 (RMS-265)
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| ICP-RM-2-RMS-266 Containment High Range Radiation Monitoring System Revision 24 (RMS-266)
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| ETE-SLR-2020-2403 North Anna Subsequent License Project - Position Paper Revision 0
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| - Sensitive Instrument Circuits During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, program provided in the UFSAR supplement.
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| The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program that, following enhancements, will be consistent with the program elements in GALL-SLR Report AMP XI.E3A, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the
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| Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed the program elements described in the applicants basis document as well as the available supporting documents.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 EQ Requirements program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEW Document Title Revision / Date CR 1018618 78 inches of water found in 1-EP-MH-25 03/13/2019 CR 1038564 NOD Audit Finding 16-04-01NS: Admin control not 09/26/2019 effective for changes for License Renewal Program CR 1084490 Wetted cables and corroded box cover in 1-BLD-MBAR- 01/31/2019 4MH03 CR 1089020 Received annunciator 1A-H8 (Manhole No. 2 Flooding) 07/18/2019 CR 1098203 34.5 kV cables submerged in the switchyard cable vaults 07/17/2019 ETE-SLR-2020-2345 North Anna Subsequent License Renewal Project Aging Revision 2 Management Evaluation Report - Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 0-AP-41 Markup Severe Weather Conditions (With Nine Attachments) Revision 76 0-GEP-34 Markup 34.5 kV Cable Inspection and Pumping Revision 1 0-MPM-1207-04 Mechanical Maintenance Support of Cable Inspection Revision 12 Markup ER-AA-CBL-103 Evaluation and Testing of Medium-Voltage Cables Revision 3 Markup During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP, as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. The staff will verify that relevant program elements are consistent with the issued version of the SLR ISG in the SER.
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| The staff reviewed the manhole inspection photographs provided by Dominion Energy and examined medium-voltage cables entering and exiting electrical manholes and noted that some cables appear to be sealed with sealant at the entry/exit points. The staff requested that Dominion Energy clarify how they will manage water accumulation inside the raceways from one manhole to the other. The staff also requested that Dominion Energy clarify how cables in
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| watertight conduits connecting raceways that could be susceptible to water intrusion will be managed. In the teleconference call on January 4, 2020, Dominion Energy clarified that GALL-SLR XI.E3 states that water accumulation and submergence could occur in a duct bank due to (a) a duct bank conduit with low points in the routing, (b) concrete cracking due to soil settlings over long period of time, (c) manhole covers not being watertight, (d) routing locations subject to high water (e.g., high seasonal cycles), and (e) wetting and submergence potential even when duct banks are sloped with intention to minimize water accumulation. Therefore, in-scope inaccessible medium-voltage power cables exposed to significant moisture are tested to determine the condition of the electrical insulation. The staff noted Dominion Energys clarification that water accumulation and cable submergence are assumed in a duct bank which is inaccessible. The licensee confirmed that periodic testing of inaccessible medium-voltage power cables is performed to determine the condition of the electrical insulation.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that, when implemented, will be consistent with the program elements in GALL-SLR Report AMP XI.E3B, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance.
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| To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed the program elements described in the applicants basis document as well as the available supporting documents.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Tittle Revision / Date CR 1005824 Wetted nonsafety-related cables found in 1-EP-MH-51 07/16/2019 CR 318509 Action items to track completion of Engineering review of 01/28/2019 the manhole inspections
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| CR 1041260 Wetted nonsafety-related cables in 1-SEC-HH-SS15 03/19/2019 CR 1135302 Water discovered in Manhole 01-BLD-MBAR-4MH03 03/10/2020 CR 1136811 Submerged cables found during annual pumping of 03/10/2020 security cable vaults ETE-SLR-2020-2350 North Anna Subsequent License Renewal Project Aging Revision 1 Management Evaluation Report - Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 0-AP-41 Markup Severe Weather Conditions (With Nine Attachments) Revision 76 0-MPM-1207-01 Mechanical Maintenance Support of Cable Inspection Revision 24 Markup (Periodic) 0-MPM-1207-03 Mechanical Maintenance Support of Cable Inspection Revision 12 Markup (Intermittent) 0-MPM-1207-04 Mechanical Maintenance Support of Cable Revision 12 Markup ER-AA-CBL-101 Evaluation and Testing of Low-Voltage Cables Revision 3 Markup During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP, as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. The staff will verify that relevant program elements are consistent with the issued version of the SLR ISG in the SER.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3C, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and
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| the staffs audit addressed the program elements described in the applicants basis document as well as the available current relevant maintenance procedures.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 EQ Requirements program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEW Document Title Revision / Date CR 1006606 Wetted cables observed in 1-SE-HH-SS6 07/16/2019 CR 1007892 54 inches of water found in 1-SE-MH-SS8 07/18/2019 CR 1014280 Found cable between 1-EE-BKR-1H1-1-A2R and 1-EE- 03/13/2019 TRAN-43N grounded CR 1014347 72 inches of water in 1-SE-MH-SS3A 08/06/2019 CR 1041235 Partially wetted non-safety cables in 1-SE-HH-SS7 07/16/2019 ETE-SLR-2020-2351 North Anna Subsequent License Renewal Project Aging Revision 1 Management Evaluation Report - Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 0-AP-41 Markup Severe Weather Conditions (With Nine Attachments) Revision 76 0-MPM-1207-01 Mechanical Maintenance Support of Cable Inspection Revision 24 Markup (Periodic) 0-MPM-1207-03 Mechanical Maintenance Support of Cable Inspection Revision 12 Markup (Intermittent) 0-MPM-1207-04 Mechanical Maintenance Support of Cable Revision 12 Markup ER-AA-CBL-101 Evaluation and Testing of Low-Voltage Cables Revision 3 Markup During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP, as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. The staff will verify that relevant program elements are consistent with the issued version of SLR ISG in the SER.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental
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| Qualification Requirements program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.42, Metal Enclosed Bus Summary of Information in the Application. The SLRA states that AMP B2.1.42, Metal Enclosed Bus, is an existing program that, following enhancements, will be consistent with the program elements in GALL-SLR Report AMP XI.E4, Metal Enclosed Bus. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed the program elements described in the applicants basis document as well as the available supporting documents.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Metal Enclosed Bus program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEW Document Title Revision / Date CR 1105784 Boots on 4160 bus connections cracked 03/12/2019 CR 324809 Bus corrosion found during breaker pm 07/17/2019 CR 358601 SER 5-09, 6.9 kV Nonsegregated Bus Failure and 03/12/2019 Complicated Scram CR 486818 Brown gel weeping from a 3000A Bus Duct Expansion 03/13/2019 Joint in U1 307 SWGR [switchgear]
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| ETE-SLR-2020-2346 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report - Metal Enclosed Bus 0-EPM-0302-17 1ER L2-14-46 Bus Duct Inspection Procedure Revision 3 Markup 0-EPM-0302-09 1H Emergency Switchgear Bus Maintenance Revision 8 Markup 1-EPM-0302-10 1J Emergency Switchgear Bus Maintenance Revision 9 Markup 2-EPM-0302-09 2H Emergency Switchgear Bus Maintenance Revision 8 Markup 2-EPM-0302-10 2J Emergency Switchgear Bus Maintenance Revision 9 Markup ETE-SLR-2020-2406 Metal Enclosed Bus Position Paper Revision 0 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.42, Metal Enclosed Bus program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.43, Fuse Holders Summary of Information in the Application. The SLRA states that AMP B2.1.43, Fuse Holders, is an existing program that will be consistent with the program elements in GALL-SLR Report AMP XI.E5, Fuse Holders. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed the program elements described in the applicants basis document as well as the available current relevant maintenance procedures and developmental references.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Fuse Holders program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 547970 Replacing fuses and blocks for 01-EP-BKR-1A1-2-A2 05/07/2014 CR 400128 NRC Question on fuse holder clip relaxation due to aging 10/22/2010 CR 378501 Elevated temperatures noted on connection points of 04/26/2010 fuse block CR 528258 Thermography of pressurizer heater fuse blocks (1-EP- 10/04/2013 CB-10D1) revealed loose connections ETE-SLR-2020-2347 North Anna Subsequent License Renewal Project - Revision 1 Aging Management Program Evaluation Report ETE-SLR-2020-2606 North Anna Subsequent License Renewal Project - Revision 1 Further Evaluation Recommended Report - SRP Section 3.6 - Electrical and Instrumentation and Controls ETE-SLR-2019-2402 Subsequent License Renewal Project Position Paper- Revision 2 Fuse Holders - North Anna Power Station 0-EPM-1202-1 Pressurizer Heater Maintenance Revision 9 During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.43, Fuse Holders program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.44, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.44, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed the program elements described in the applicants basis document as well as the available supporting documents.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 338536 Thermography found elevated temperature on 1-EE- 06/17/2009 BKR-1J1-2S-K1 CR 3553471 Found elevated temperature on terminal lugs on 2-EP- 10/19/2009 BKR-558 CR 375492 Conductor at lug junction shows several broken strands 08/07/2010 CR 1031882 Cable lug in 25H1 needs to be replaced (found during 03/26/2016 wiring verifications)
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| ETE-SLR-2020-2348 North Anna Subsequent License Renewal Project - Revision 1 Aging Management Program Evaluation Report -
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| Electrical Cable Connections Not Subject to 10CFR 50.49 Environmental Qualification Requirements ETE-SLR-2019-2409 Subsequent License Renewal Project Position Paper- Revision 0 Electrical Cable Connections Sampling Methodology -
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| North Anna Power Station During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| During the audit the staff reviewed the applicant provided position paper, ETE-SLR-2019-2409 and verified that connector type (e.g., lug, terminal, Conax') is included as a category in selection of the sampling basis population for inspection of in-scope electrical connections.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.44, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B2.1.45, High-Voltage Insulators Summary of Information in the Application. The SLRA states that AMP B2.1.45, High-Voltage Insulators, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E7, High-Voltage Insulators, as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, Dominion Energy had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed the program elements described in the applicants basis document as well as the available supporting documents.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the High-Voltage Insulators program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 520790 IER L3-13-30, automatic reactor scram following a 07/16/2013 500 kV insulator flashover CR 513940 IER L3-13-13, loss of one phase of off-site power causes 05/01/2013 loss of maintenance cooling CR 582753 Switchyard thermography needed within 7 days of wind 06/20/2015 exceeding 50 mph CR 1023876 PAG perform thermography of switchyard due to wind 01/12/2016 exceeding 50 mph ETE-SLR-2020-2349 North Anna Subsequent License Renewal Project - Revision 0 Aging Management Program Evaluation Report -
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| High-Voltage Insulators ETE-SLR-2020-2410 North Anna Subsequent License Renewal Project - Revision 0 Position Paper - High-Voltage Insulators ETE-SLR-2020-2016 North Anna Subsequent License Renewal Project - Revision 0 Integrated Plant assessment Report - Electrical Components CIGRE-Calgary Assessment of electrical and mechanical performance of 08/27/2007 2007 toughened glass insulators removed from existing high-voltage lines During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP
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| as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. The staff will verify that relevant program elements are consistent with the issued version of the SLR ISG in the SER.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA Section A1.45, High-Voltage Insulators program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was adequate description of SLRA Section A1.45. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description SLRA AMP B3.1 Fatigue Monitoring Program Summary of Information in the Application. The SLRA states that AMP B3.1, Fatigue Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Fatigue Monitoring program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020- Subsequent License Renewal Project Aging 08/2020 2301, Attachment 1 Management Program Evaluation Report Fatigue Monitoring North Anna Power Station NA North Anna Operating Experience Detail Report -Fatigue Printed Monitoring 09/10/2020 NA North Anna Operating Experience List Report - Fatigue Printed Monitoring 09/10/2020 1-PT-160 RCS Transient Cycle Log Review Revision 13 2-PT-160 RCS Transient Cycle Log Review Revision 13 1-LOG-13 RCS Transient Cycle Log Revision 8 2-LOG-13 RCS Transient Cycle Log Revision 8 1-AP-2.2 Fast Load Reduction Revision 35 WCAP -18503 Resolution of North Anna Power Station Units 1 & 2 Revision 1 Time-Limited Aging Analyses for Subsequent License Renewal
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| Document Title Revision / Date CN-SDA-II-18-007 Transient Basis for North Anna Units 1 and 2 80-Year Revision 1 Subsequent License Renewal TLAA Evaluations During the audit, the staff verified Dominion Energys claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP B3.1, Fatigue Monitoring, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B3.2, Neutron Fluence Monitoring Program Summary of Information in the Application. The SLRA states that AMP B3.2, Neutron Fluence Monitoring, is an existing program that is consistent with the program elements in GALL-SLR Report AMP X/M2, Neutron Fluence Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Neutron Fluence Monitoring program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020- Subsequent License Renewal Project Aging 09/2020 2302, Attachment 1 Management Program Evaluation Report Neutron Fluence Monitoring North Anna Power Station 1-PT-54 Vessel Irradiation Program Revision 9 2-PT-54 Vessel Irradiation Program Revision 9 ER-AA-RVI-101 Reactor Vessel Integrity Program Revision 6 N/A North Anna Operating Experience List Report - Reactor Printed Vessel Material Surveillance 09/05/2019 During the audit, the staff verified Dominion Energys claim that the acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| During the audit, the staff identified an exception associated with the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements. This staff-identified exception will be addressed in
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| the SER. The staff verified that those aspects of these program elements not associated with this staff-identified exception are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA B3.2, Neutron Fluence Monitoring provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA AMP B3.3, Environmental Qualification (EQ) of Electric Equipment Summary of Information in the Application. The SLRA states that AMP B3.3, Environmental Qualification of Electric Equipment, is an existing program that is consistent with the program elements in GALL-SLR Report AMP X.E1, Environmental Qualification of Electric Components. To verify this claim of consistency, the staff audited the SLRA AMP.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the EQ of Electric Equipment program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 1012598 Determine EQ Program Impact from Steris-Isomedix 03/08/2019 Radiation Dose Part 21 CR 1040813 Part 21 Evaluation for ASCO EQ SOVs [solenoid-operated 03/08/2019 valves] Requires Revision of EQ Documentation CR 1044269 Limitorque MOV [motor operated valve] EQ QDR File 03/08/2019 Discrepancies Related to Beta Radiation CR 1163439 EQ Program Review Required for EPRI NP-1558 revision 01/06/2021 ETE-SLR-2019-2001 North Anna Subsequent License Renewal Project - Revision 0 Regulated Event Report - 10 CFR 54.4(a)(3)
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| Environmental Qualification CM-AA-EQ-10 Fleet EQ Program Description Revision 5 CM-NA-EQ-100 Environmental Qualification Program Implementation Revision 6 EE-0014 Determination of Applicability of 10 CFR 50.49 and Revision 2 Specification Requirements for 10 CFR 50.49 Equipment or Safety-Related Equipment Located in a Mild Environment EQ-0079 Electrical Equipment Environmental Qualification Design Revision 0 Basis for North Anna and Surry Power Stations ETE-SLR-2019-2303 North Anna Subsequent License Renewal Project - Aging Revision 1 Management Program Evaluation Report - Environmental Qualification of Electric Equipment
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| Document Title Revision / Date N/A EQ Master List 09/14/2020 During the audit, the staff verified that for the program elements that Dominion Energy declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
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| During the audit, the staff noted that the licensee generated condition report CR 1163439 during the audit to evaluate whether the recent revision to the EPRI Report NP-1558 has any adverse effects on the qualification of electric equipment at NAPS (specifically related to the activation energy used to determine the qualification of components).
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA AMP A3.4, Environmental Qualification of Electric Equipment provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
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| SLRA TLAA Section 4.1.1, Identification of Time-Limited Aging Analyses and TLAA Section 4.1.4, Identification of Exemptions Summary of Information in the Application. SLRA Section 4.1.1, Identification of Time-Limited Aging Analyses, discusses the methodology for identifying TLAAs. SLRA Section 4.1.4, Identification of Exemptions, discusses the methodology for identifying plant-specific exemptions that are in effect and based on TLAAs. To verify that Dominion Energys methodology was adequate for identifying TLAAs and plant-specific exemptions that are in effect and based on TLAAs, the staff audited available documents on the ePortal.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the program.
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| The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020-2701 Identification of Time-Limited Aging Analyses (TLAA) - Revision 0 key word searches During the audit, the staff verified that the applicants methodology supports identifying TLAAs in accordance with disposition of 10 CFR 54.21(c). During the audit the staff made the following observations, which will be used in SER Section 4.1:
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| The staff reviewed ETE-SLR-2020-2701 and confirmed that current licensing basis and design basis documentation were searched to identify potential TLAAs. The staff noted that specific key words were used during this search that would identify potential TLAAs.
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| The staff reviewed ETE-SLR-2020-2701 and confirmed that each potential TLAA was reviewed against the six criteria of 10 CFR 54.3(a) and that those that met all six criteria were identified as TLAAs which require evaluation for the subsequent period of extended operation.
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| The staff reviewed ETE-SLR-2020-2701 and confirmed that a search of docketed licensing correspondence, the operating license, and the UFSAR identified the active exemptions currently in effect pursuant to 10 CFR 50.12.
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| The staff reviewed ETE-SLR-2020-2701 and confirmed that these exemptions were then reviewed to determine whether the exemption was based on a TLAA and that no 10 CFR 50.12 exemptions involve a TLAA as defined in 10 CFR 54.3.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| SLRA TLAA Section 4.2.2, Upper-Shelf Energy Summary of Information in the Application. SLRA Section 4.2.2, Upper-Shelf Energy, discusses the evaluation of the time-limited aging analysis (TLAA) that assesses the projected reduction in the upper-shelf energy (USE) properties of reactor pressure vessel (RPV) base metal and weld components through the licensed period of the reactor units. Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the USE program. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title or Description Revision / Date CT-CALC-NFL-SM-1008 Pressurized Thermal Shock (PTS) Screening Revision 0, Calculations for Surry and North Anna Units 1 and 2 02/05/1996 Spreadsheet extract Heading: Extracted from RVIPCALC_SM- No Date from calculation SM- 1008_Rev-0_ADD-M - Macros Embedded SPS 1008 NAPS Rheinstahl Huttenwerke Ladle analysis datasheet for Upper Shell Forging 05 06/24/1969 data sheet of Unit 1 (Heat 990286/295213)
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| (PROPRIETARY)
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| Rheinstahl Huttenwerke Ladle analysis datasheet for Upper Shell Forging 05 07/22/1969 data sheet of Unit 2 (Heat 990598/291396)
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| (PROPRIETARY)
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| PWROG-17090-NP-A Generic Rotterdam Forging and Weld Initial Upper- Revision 0, Shelf Energy Determination 01/2020 PWROG-18005-NP Determination of Unirradiated RTNDT [reference Revision 2, temperature nil ductility] and Upper-Shelf Energy 09/2019 Values of the North Anna Units 1 and 2 Reactor Vessel Materials BAW-2224 North Anna Units 1 and 2 Response to Closure Revision 1, Letter for NRC Generic Letter 92-01 07/1994
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| Document Title or Description Revision / Date WCAP-15112 North Anna Units 1 and 2 WOG [Westinghouse Revision 2, Owners Group] Reactor Vessel 6-Year Evaluation 03/2001 Mini group Heatup and Cooldown Limit Curves for Normal Operation LTR-SDA-19-099 Evaluation of Conservatisms and Margins Revision 0, Associated with North Anna Units 1 and 2 Reactor 03/30/2020 Vessel Integrity Extended Beltline Evaluations for Subsequent License Renewal WCAP-18364-NP North Anna Units 1 and 2 Time-Limited Aging Revision 1, Analysis on Reactor Vessel Integrity for Subsequent 03/2020 License Renewal (SLR)
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| WCAP-18015-NP Extended Beltline Pressure Vessel Fluence Revision 2, Evaluations Applicable to North Anna Units 1 & 2 09/2018 BAW-2356 Analysis of Capsule W - Virginia Power - North 09/1999 Anna Unit No. 1 Nuclear Power Plant - Reactor Vessel Material Surveillance Program BAW-2376 Analysis of Capsule W - Virginia Power - North 08/2000 Anna Unit No. 2 Nuclear Power Plant - Reactor Vessel Material Surveillance Program WCAP-17539-NP Sequoyah Units 1 and 2 Time-Limited Aging Revision 0, Analysis on Reactor Vessel Integrity 03/2012 PWROG-19047-P North Anna Units 1 and 2 Reactor Vessels Low Revision 0, (PROPRIETARY) Upper-Shelf Fracture Toughness Equivalent 05/2020 Margins Analysis During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. No significant plant-specific OpE associated with SLRA TLAA 4.2.2, Cracking Associated with Weld Deposited Cladding, was noted by the staff during its review. However, the staff acknowledges that OpE related to the USE TLAA is generated through the applicants implementation of its reactor vessel materials surveillance program (refer to SLRA Section B2.1.19), which is based on the requirements 10 CFR Part 50, Appendix H. The relevant OpE and associated RPV surveillance data are summarized in RPV surveillance reports that are generated in accordance with reporting requirements specified in the Part 50, Appendix H rule. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| Note (e) in SLRA Tables 4.2.2-1 and 4.2.2-2 states that data for the RPV materials identified by the note were obtained from Dominion Energy calculation number SM-1008. Since the staff could not locate the weight percent copper (wt. % Cu) values of the RPV beltline materials identified by Note (e) in calculation number SM-1008, the staff requested Dominion Energy to locate the values in the calculation. Dominion Energy provided spreadsheet extracts from calculation number SM-1008 in the audit portal that showed the wt. % Cu values for the RPV beltline materials identified by Note (e) of SLRA Tables 4.2.2-1 and 4.2.2-2.
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| Note (a) in SLRA Tables 4.2.2-1 and 4.2.2-2 cite PWR Owners Group (PWROG)-18005-NP.
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| Note (c) in Tables 9 and 10 of PWROG-18005-NP states that the wt. % Cu values for the noted RPV beltline weld or forging were based on a ladle analysis. The staff requested to see documentation of the ladle analysis to verify the reliability of the wt. % Cu values from this analysis. Dominion Energy explained that the ladle analysis is a part of certified material test reports from the original RPV manufacturer and provided in the audit portal proprietary datasheets for two forgings in the RPV beltline of NAPS, Units 1 and 2.
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| SLRA Tables 4.2.2-1 and 4.2.2-2 cite PWROG-18005-NP as the source of the initial USE values of the RPV beltline and extended beltline of NAPS, Units 1 and 2. Section 3.0 of Attachment 1 to PWROG-18005-NP states that USE is calculated based on an interpretation of the 1982 version of American Society for Testing and Materials (ASTM) E185 (ASTM E185-82) that is best explained by the 2016 version, ASTM E185-16.
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| The staff requested Dominion Energy to confirm that the initial USE data were from already existing data (e.g., data from certified material test reports or RPV surveillance program) and that Dominion Energy calculated USE from this data using ASTM E185-82 and referred to ASTM E185-16 for clarification of the definition of USE in ASTM E185-82. Dominion Energy confirmed the staffs understanding.
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| Note (c) in SLRA Table 4.2.2-1 cites topical report PWROG-17090-NP-A for the initial USE value of 56 foot-pound (ft-lb) for Inlet Nozzle Forging 11 of NAPS, Unit 1. The NRC Safety Evaluation (SE) in PWROG-17090-NP-A states that generic values in the topical report can be used only if no measured values of unirradiated USEare available for the specific RV
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| [reactor vessel] material under consideration. Table 7 of Attachment 2 to PWROG-18005-NP shows Charpy V-Notch energy measured values for Inlet Nozzle Forging 11. The staff requested Dominion Energy to clarify that even though Charpy V-Notch energy measured values for Inlet Nozzle Forging 11 exist, as shown in Table 7 of Attachment 2 to PWROG-18005-NP, USE cannot be defined based on those values because there is no % shear data at the highest temperature shown, and that thus generic values from PWROG-17090-NP-A were used for Inlet Nozzle Forging 11. Dominion Energy confirmed the staffs understanding.
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| SLRA Table 4.2.2-2 cites PWROG-18005-NP for the initial USE values of Inlet Nozzle Forging 11 and Outlet Nozzle Forging 12 of NAPS, Unit 2. Table 6 of Attachment 1 to PWROG-18005-NP compares the original unirradiated (initial) USE values with the updated unirradiated USE values. The staff noted large increases in the initial USE values for Inlet Nozzle Forging 11 (60 ft-lb to 75 ft-lb) and Outlet Nozzle Forging 12 (52 ft-lb to 60 ft-lb) of NAPS, Unit 2. All other changes in initial USE values in Tables 5 and 6 of Attachment 1 to PWROG-18005-NP are either small increases, negative (meaning initial USE decreased), or have an explanation. The staff noted that the original initial USE values for Inlet Nozzle Forging 11 and Outlet Nozzle Forging 12 of NAPS, Unit 2 came from the UFSAR and are therefore current licensing basis (CLB) values. The staff requested Dominion Energy to explain the reason for the CLB initial USE values being so much less compared to those calculated from the data in Tables 7 and 8 for Inlet Nozzle Forging 11 and Outlet Nozzle Forging 12, respectively, of Attachment 3 to PWROG-18005-NP. Dominion Energy explained that the current level of detail in determining initial USE values did not exist at the time the CLB values of initial USE were established. Dominion Energy also explained that the CLB values are historical data as noted in the UFSAR, and initial USE values were from the highest test temperature reported as noted in the UFSAR.
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| The staff also audited the summary description of the USE TLAA provided in the UFSAR supplement. The staff verified this summary description is consistent with the description in the SRP-SLR.
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| SLRA TLAA Section 4.2.3, Pressurized Thermal Shock Summary of Information in the Application. SLRA Section 4.2.3, Pressurized Thermal Shock, discusses Dominion Energys Pressurized Thermal Shock (PTS) analyses for the RPVs at NAPS, Units 1 and 2. The TLAA (henceforth referred to as the TLAA on PTS) applies to RPV base metal and weld components that are made from ferritic steel materials (e.g., carbon steels or low alloy steels) and are exposed to a reactor coolant with neutron flux environment, with neutron fluence being the time-dependent aging parameter that is evaluated in the TLAA. The calculations apply to those RPV components that are located in the beltline of the RPV (including RPV extended beltline components).
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| Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii) and stated that the PTS analyses have been projected to the end of the subsequent period of extended operation. To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the program.
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| The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date WCAP-18364-NP North Anna Units 1 and 2 Time-Limited Aging Analysis Revision 1, on Reactor Vessel Integrity for Subsequent License 03/2020 Renewal (ADAMS Accession No. ML20246G701)
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| PWROG-18005-NP Determination of Unirradiated RTNDT and Upper-Shelf Revision 2, Energy Values of the North Anna Units 1 and 2 Reactor 09/2019 Vessel Materials (ADAMS Accession No. ML20246G706)
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| WCAP-11777 Analysis of Capsule U from the Virginia Electric and 02/1988 Power Company North Anna Unit 1 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12242A089)
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| BAW-1638 Analysis of Capsule V - Virginia Electric & Power 03/1981 Company - North Anna Unit No. 1 - Reactor Vessel Materials Surveillance Program (ADAMS Accession No. ML12242A088)
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| BAW-2356 Analysis of Capsule W - Virginia Power - North Anna 09/1999 Unit No. 1 Nuclear Power Plant (ADAMS Accession No. ML12242A091)
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| WCAP-12497 Analysis of Capsule U from the Virginia Electric and 01/1990 Power Company North Anna Unit 2 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12242A096)
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| BAW-1794 Analysis of Capsule V - Virginia Electric & Power 10/1983 Company - North Anna Unit No. 2 - Reactor Materials Surveillance Program (ADAMS Accession No. ML12242A094)
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| Document Title Revision / Date BAW-2376 Analysis of Capsule W - Virginia Power - North Anna 08/2000 Unit 2 Nuclear Power Plant (ADAMS Accession No. ML12298A446)
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| WCAP-15224 Analysis of Capsule Y from the Tennessee Valley 06/1999 Authority Sequoyah Unit 1 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12298A446)
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| WCAP-15224-ERR Analysis of Capsule Y from the Tennessee Valley 08/25/1999 Authority Sequoyah Unit 1 Reactor Vessel Radiation Surveillance Program - Errata Sheet for WCAP-15224 (ADAMS Accession No. ML20212A184)
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| WCAP-15320 Analysis of Capsule Y from the Tennessee Valley 12/1999 Authority Sequoyah Unit 2 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12243A022)
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). During the audit, the staff made the following observations:
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| The staff reviewed similar documents as reviewed in Audit Report Section, SLRA TLAA Section 4.2.4, Adjusted Reference Temperature. The staff notes that adjusted reference temperature (ART) is an important input to the RTPTS calculation. The ART is calculated using the surface fluence value when applied to the RTPTS calculation. The staffs audit described in Audit Report Section, SLRA TLAA Section 4.2.4, Adjusted Reference Temperature, is applicable here.
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| The staff performed confirmatory calculations of the applicants RTPTS values listed in Tables 4.2.3-1 and 4.2.3-2.
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
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| Consistent with the guidance in SRP-SLR Section 3.1.2.2.3, Item 2, the OpE for the TLAA on PTS is provided by the applicants RPV surveillance capsule reports for NAPS and applicable sister plants that apply to the TLAA. Since the applicant is required to submit the reports to the NRC in accordance with specified reporting requirements in 10 CFR Part 50, Appendix H, the staff did not perform a keyword search of relevant terms (e.g., 1RPV, capsule, etc.) that may apply to the TLAA.
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| Instead, the staff performed a search of the NRCs ADAMS database to locate those RPV surveillance capsule reports that apply to the TLAA on PTS, including applicable RPV sister plant reports.
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| The staff also audited the description of the SLRA TLAA Pressurized Thermal Shock provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
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| - 101 -
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| SLRA TLAA Section 4.2.4, Adjusted Reference Temperature Summary of Information in the Application. SLRA Section 4.2.4, Adjusted Reference Temperature, discusses Dominion Energys ART analyses for the RPVs at NAPS. The TLAA (henceforth referred to as the TLAA on ART) applies to RPV base metal and weld components that are made from ferritic steel materials (e.g., carbon steels or low alloy steels) and are exposed to a reactor coolant with neutron flux environment, with neutron fluence being the time-dependent aging parameter that is evaluated in the TLAA. The TLAA on ART includes the applicants ART calculations for the inside and outside 1/4-thickness flaws that are postulated for the RPV components. The calculations apply to those RPV components that are located in the beltline of the RPV (including RPV extended beltline components).
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| Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii) and stated that the ART analyses have been projected to the end of the subsequent period of extended operation. To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. Consistent with the guidance in SRP-SLR Section 3.1.2.2.3, Item 2, the OpE for the TLAA on ART is provided by the applicants RPV surveillance capsule reports for NAPS and applicable sister plants that apply to the TLAA. Since the applicant is required to submit the reports to the NRC in accordance with specified reporting requirements in 10 CFR Part 50, Appendix H, the staff did not perform a keyword search of relevant terms (e.g., RPV, capsule, etc.) that may apply to the TLAA. Instead, the staff performed a search of the NRCs ADAMS database to locate those RPV surveillance capsule reports that apply to the TLAA on ART, including applicable RPV sister plant reports. The relevant RPV surveillance capsule reports for TLAA on ART are specified in the Relevant Documents Reviewed table below.
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| During its audit, the staff reviewed documentation provided by Dominion Energy. The staff reviewed the following relevant documents.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date WCAP-18363-NP North Anna Units 1 and 2 Heatup and Cooldown Limit Revision 1, Curves for Normal Operation 03/2020 WCAP-18364-NP North Anna Units 1 and 2 Time-Limited Aging Analysis Revision 1, on Reactor Vessel Integrity for Subsequent License 03/2020 Renewal (ADAMS Accession No. ML20246G701)
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| PWROG-18005-NP Determination of Unirradiated RTNDT and Upper-Shelf Revision 2, Energy Values of the North Anna Units 1 and 2 Reactor 09/2019 Vessel Materials (ADAMS Accession No. ML20246G706)
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| WCAP-11777 Analysis of Capsule U from the Virginia Electric and 02/1988 Power Company North Anna Unit 1 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12242A089)
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| BAW-1638 Analysis of Capsule V - Virginia Electric & Power 03/1981 Company - North Anna Unit No. 1 - Reactor Vessel Materials Surveillance Program (ADAMS Accession No. ML12242A088)
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| BAW-2356 Analysis of Capsule W - Virginia Power - North Anna 09/1999 Unit No. 1 Nuclear Power Plant (ADAMS Accession No. ML12242A091)
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| - 102 -
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| Document Title Revision / Date WCAP-12497 Analysis of Capsule U from the Virginia Electric and 01/1990 Power Company North Anna Unit 2 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12242A096)
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| BAW-1794 Analysis of Capsule V - Virginia Electric & Power 10/1983 Company - North Anna Unit No. 2 - Reactor Materials Surveillance Program (ADAMS Accession No. ML12242A094)
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| BAW-2376 Analysis of Capsule W - Virginia Power - North Anna 09/2000 Unit 2 Nuclear Power Plant (ADAMS Accession No. ML12298A446)
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| WCAP-15224 Analysis of Capsule Y from the Tennessee Valley 06/1999 Authority Sequoyah Unit 1 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12243A017)
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| WCAP-15224-ERR Analysis of Capsule Y from the Tennessee Valley 08/25/1999 Authority Sequoyah Unit 1 Reactor Vessel Radiation Surveillance Program - Errata Sheet for WCAP-15224 (ADAMS Accession No. ML20212A184)
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| WCAP-15320 Analysis of Capsule Y from the Tennessee Valley 12/1999 Authority Sequoyah Unit 2 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML12243A022)
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). During the audit, the staff made the following observations:
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| The staff reviewed WCAP-18363 and noted that, while the applicant performed Master Curve calculations for certain RPV location, the applicant did not apply Master Curve results to the ART TLAA credited in the SLRA.
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| The staff reviewed WCAP-18364 and verified via spot-check that the updated 80-year fluence values were correctly applied to the ART TLAA.
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| The staff reviewed WCAP-18364 and noted that the applicant performed an evaluation of unirradiated RTNDT based upon updated information, as part of the ART TLAA.
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| The staff reviewed WCAP-18364 and noted that the applicant provided a description of surveillance capsule withdrawal schedule.
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| The staff reviewed WCAP-18364 and noted that the applicant provided a description of the licensing basis behind determining chemistry factor when surveillance data is available.
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| The staff reviewed PWROG-18005 and noted the details captured in this report on the unirradiated RTNDT evaluation, including analysis of Charpy impact testing results from Certified Material Test Reports.
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| The staff reviewed several surveillance capsule reports and verified via spot-check that measured RTNDT values were appropriately accounted for in Table A.2-1 of WCAP-18364.
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| The staff performed confirmatory calculations of applicants ART values listed in Tables 4.2.4-1 through 4.2.4-8.
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
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| The staff also audited the description of the SLRA TLAA Adjusted Reference Temperature provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR SLRA TLAA Section 4.2.5, Pressure-Temperature Limits Summary of Information in the Application. SLRA Section 4.2.5. Pressure-Temperature (P-T)
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| Limits, discusses the evaluation of the TLAA that assesses the P-T limits projected through the licensed period of the reactor units. Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).
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| The P-T limit curves are determined in accordance with the requirements of 10 CFR 50, Appendix G, which incorporates the ASME Code, Section XI, Appendix G. The P-T limits for the current operating period, specifically 50.3 EFPY for Unit 1, and 52.3 EFPY for Unit 2, are presently maintained in the Technical Specifications for Units 1 and 2.
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| For the subsequent license renewal period of operation, the P-T limits will be updated through the 10 CFR 50.90 process at a future date. The P-T limits for the subsequent period of extended operation will be updated prior to exceeding the EFPY for which they remain valid.
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| The Reactor Vessel Material Surveillance program and plant Technical Specifications will ensure that updated P-T limits based upon updated ART values will be submitted to the NRC for approval prior to exceeding the period of applicability for Units 1 and 2.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the P-T Limits TLAA. The staff will document its review of this information in the SER.
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| During its audit, the staff reviewed documentation provided by Dominion Energy. The staff reviewed the following relevant documents.
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| RELEVANT DOCUMENTS REVIEWED Document Title or Description Revision / Date WCAP-15112 North Anna Units 1 and 2 WOG Reactor Vessel Revision 2, Evaluation Minigroup Heatup and Cooldown Limit Curves 03/ 2001 for Normal Operation During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
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| - 104 -
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| SLRA TLAA Section 4.2.6, Low Temperature Overpressure Protection Summary of Information in the Application. SLRA Section 4.2.6, Low Temperature Overpressure Protection, discusses Dominion Energys low temperature overpressure protection (LTOP) analyses for the reactor vessels (RVs) at NAPS, Units 1 and 2. The LTOP system is required by Technical Specification Limited Condition for Operation 3.4.12. The pressurizer power operated relief valves provide the automatic relief capability during the design basis mass input and the design basis heat input transients to automatically prevent the reactor coolant system pressure from exceeding the P-T limits, which are based on Appendix G to 10 CFR 50. LTOP system setpoints are based on the P-T limits calculation which is a TLAA.
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| Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii) and stated that the LTOP analyses have been projected to the end of the subsequent period of extended operation. To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. During its audit, the staff reviewed documentation contained in the SLRA, provided by the applicant via the ePortal, and separately available in NRCs ADAMS due to other regulatory requirements. To prevent LTOP transients that would produce excursions exceeding the limits in Appendix G of 10 CFR Part 50, PWRs have a system to relieve pressure in the RV. Radiation embrittlement of RPV materials is a concern because it causes a reduction in the capability of the material to withstand the presence of cracks and a reduction in the fracture toughness of the material. Radiation embrittlement effectively shifts the fracture toughness trend curve, determined using unirradiated materials, to higher temperatures. The LTOP system is designed to prevent the reactor coolant system from exceeding the pressure-temperature limits specified in 10 CFR 50, Appendix G.
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| The guidance in SRP-SLR Section 3.1.2.2.3, Item 2 addresses the increase in embrittlement with increasing neutron fluence. The reactor vessel material surveillance program, specified in 10 CFR 50, Appendix H, is a program that monitors this effect. Therefore, the OpE for the TLAA on LTOP, like other TLAAs impacted by embrittlement, is provided by the applicants RV surveillance capsule summary technical reports for NAPS, Units 1 and 2, and applicable surveillance data from sister plants. Submittal of these reports is a requirement under 10 CFR Part 50, Appendix H. Consequently, the staff did not perform a keyword search of relevant terms (e.g., RV, capsule, etc.) that could apply to the TLAA. Instead, the staff performed a search of the NRCs ADAMS to locate the Appendix H summary technical reports that apply to the TLAA on LTOP, including applicable sister plant reports. These are included in the table below. The staff will document its review of this information in the SER with the exception of information regarding the P-T limit curves, because this topic is dispositioned in accordance with 10 CFR 54.21(c)(1)(iii) in TLAA Section 4.2.5.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date WCAP-18363-NP North Anna Units 1 and 2 Heatup and Cooldown Limit Revision 1, Curves for Normal Operation 03/2020 WCAP-18364-NP North Anna Units 1 and 2 Time-Limited Aging Analysis on Revision 1, Reactor Vessel Integrity for Subsequent License Renewal 03/2020 (ADAMS Accession No. ML20246G701)
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| PWROG-18005-NP Determination of Unirradiated RTNDT and Upper-Shelf Revision 2, Energy Values of the North Anna Units 1 and 2 Reactor 09/2019 Vessel Materials (ADAMS Accession No. ML20246G706)
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| - 105 -
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| Document Title Revision / Date WCAP-11777 Analysis of Capsule U from the Virginia Electric and Power 02/1988 Company North Anna Unit 1 Reactor Vessel Radiation Surveillance Program (Proprietary)
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| BAW-1638 Analysis of Capsule V - Virginia Electric & Power 03/1981 Company - North Anna Unit No. 1 - Reactor Vessel Materials Surveillance Program (Proprietary)
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| BAW-2356 Analysis of Capsule W - Virginia Power - North Anna Unit 09/1999 No. 1 Nuclear Power Plant (Proprietary)
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| WCAP-12497 Analysis of Capsule U from the Virginia Electric and Power 01/1990 Company North Anna Unit 2 Reactor Vessel Radiation Surveillance Program (ADAMS Accession No. ML20012C012)
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| BAW-1794 Analysis of Capsule V - Virginia Electric & Power 10/1983 Company - North Anna Unit No. 2 - Reactor Materials Surveillance Program (Proprietary)
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| BAW-2376 Analysis of Capsule W - Virginia Power - North Anna 08/2000 Unit 2 Nuclear Power Plant (Proprietary)
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| WCAP-15224 Analysis of Capsule Y from the Tennessee Valley Authority 06/1999 Sequoyah Unit 1 Reactor Vessel Radiation Surveillance Program (Proprietary)
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| WCAP-15224-ERR Analysis of Capsule Y from the Tennessee Valley Authority 08/25/1999 Sequoyah Unit 1 Reactor Vessel Radiation Surveillance Program - Errata Sheet for WCAP-15224 (ADAMS Accession No. ML20212A184)
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| WCAP-15320 Analysis of Capsule Y from the Tennessee Valley Authority 12/1999 Sequoyah Unit 2 Reactor Vessel Radiation Surveillance Program (Proprietary)
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). Observations to SLRA Section 4.2.4, Adjusted Reference Temperature, will be relevant to this TLAA section as well.
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
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| SLRA TLAA Section 4.3, Metal Fatigue Summary of Information in the Application. SLRA Section 4.3 Metal Fatigue discusses the analyses for the following components and systems:
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| Transient Cycle Projections for 80 years (SLRA Section 4.3.1)
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| ASME Code, Section III, Class1 Fatigue Analyses (SLRA Section 4.3.2)
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| United States of America Standards (USAS) (American National Standards Institute (ANSI)) B31.1 Allowable Stress Analyses (SLRA Section 4.3.3)
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| Environmentally-Assisted Fatigue (EAF) (SLRA Section 4.3.4)
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| Reactor Vessel Internals Fatigue Analyses (SLRA Section 4.3.5)
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| - 106 -
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| High Energy Line Break Analyses (SLRA Section 4.3.6)
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i) for the following TLAAs.
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| : 1. ASME Code, Section III, Class 1 Fatigue Analyses (Section 4.3.2)
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| : 2. Class 1 USAS (ANSI) B31.7 Piping (Section 4.3.2.7)
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| : 3. USAS (ANSI) B31.1 Allowable Stress Analyses (Section 4.3.3)
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| : 4. Reactor Vessel Internals Fatigue Analyses (Section 4.3.5)
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| : 5. High Energy Line Break Analyses (Section 4.3.6)
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii) for the following:
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| ASME Code, Section III, Class 1 Fatigue Analyses (Section 4.3.2) o Control Rod Drive Mechanism (Section 4.3.2.1) o Pressurizer (including Nozzle FSWOLs [full structural weld overlays])
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| (Section 4.3.2.2) o Reactor Coolant Pump (Section 4.3.2.3) o Reactor Vessel (Section 4.3.2.4) o Steam Generators (including Unit 1 Inlet Nozzle SWOL [structural weld overlay])
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| (Section 4.3.2.5) o Pressurizer Surge Line (Section 4.3.2.6) o Loop Stop Isolation Valves (Section 4.3.2.8) o ASME Code, Section III, Class 1 Component Fatigue Waivers (Section 4.3.2.9)
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| Environmentally-Assisted Fatigue (Section 4.3.4)
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| To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAAs listed above. The staff will address issues identified but not resolved in this report in the SER for the following TLAAs:
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| ASME Code, Section III, Class 1 Fatigue Analyses (SLRA Section 4.3.2) o Pressurizer Surge Line (SLRA Section 4.3.2.6) o Class 1 USAS (ANSI) B31.7 Piping (SLRA Section 4.3.2.7)
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| Environmentally-Assisted Fatigue (SLRA Section 4.3.4)
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| High Energy Line Break Analyses (SLRA Section 4.3.6)
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Metal Fatigue TLAA. The staff will document its review of this information in the SER.
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| - 107 -
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020- Subsequent License Renewal Project Aging 08/2020 2301, Attachment 1 Management Program Evaluation Report Fatigue Monitoring North Anna Power Station WCAP-18503 Resolution of North Anna Power Station Units 1 & 2 Revision 1 Time-Limited Aging Analyses for Subsequent License 07/2020 Renewal CN-SDA-II-18-007 Transient basis for North Anna Units 1 and 2 80-year Revision 1 Subsequent License Renewal TLAA Evaluations 1701098.304P Overall Environmentally-Assisted Fatigue Screening for Revision 1 North Anna Subsequent License Renewal (SLR) 1701098.403P Defemination of Final Set of Environmentally-Assisted Revision 1 Fatigue (EAF) Sentinel Locations for NAPS Units 1 and Subsequent License Renewal LTR-SDA-II-19-08 Environmentally-Assisted Fatigue Screening Results for Revision 2 North Anna Unit 1 and Unit 2 LTR-SDA-II-19-16 North Anna Units 1 and 2 Environmentally-Assisted Revision 1 Fatigue Screening - Safety Class 1 Piping and Equipment Transient Section Definition ETE-SLR-2020-2231 North Anna Subsequent License Renewal Project - Revision 0 Evaluation Report - ANSI B31.1 Allowable Stress Analyses WCAP-18542 North Anna Units 1 and 2 ASME Section XI Appendix L Revision 0 Flow Tolerance Evaluation for Safety Injection, Charging and Accumulator Nozzles ETE-SLR-2020- Subsequent License Renewal Project Aging 08/2020 2301, Attachment 1 Management Program Evaluation Report Fatigue Monitoring North Anna Power Station WCAP-18503 Resolution of North Anna Power Station Units 1 & 2 Revision 1, Time-Limited Aging Analyses for Subsequent License 07/2020 Renewal N/A North Anna Operating Experience Detail Report -Fatigue Printed Monitoring 09/10/2020 N/A North Anna Operating Experience List Report - Fatigue Printed Monitoring 09/10/2020 For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| The staff reviewed ETE-SLR-2020-2231 and confirmed that the projected cycles provided in SLRA Table 4.3.3-1 80-Year Transient Cycle Projections for USAS (ANSI)
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| B31.1 Piping are reasonable and are supported by operation logs, maintenance testing, surveillance, procedures and/or conservative assumptions.
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| The staff reviewed WCAP-18503 and CN-SDA-II-18-007, which support the information SLRA Table 4.3.1-1, and confirmed the following:
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| - 108 -
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| o A review of plant information/data (e.g., cycle count procedure/logs, operator interview, license event reports (LERs), power history data) was performed to identify the number of cumulative cycles for each transient type that occurred at Units 1 and 2 up to November 8, 2017.
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| o Baseline cycle counts were, in general, projected to an 80-year operating life based on the actual accumulation history over the entire operating time of the plant or from last 10 years (November 8, 2007 - November 8, 2017), when appropriate.
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| o Certain transients (i.e., transients not applicable or fatigue insignificant) were assessed and conservative assumptions were made for 80-year projections.
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| o Fatigue analyses were not performed using 80-year cycle projections. Rather, cycle projections were only used to aid and inform the applicants aging management approaches.
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| The staff reviewed 1701098.403P, which supports the information in SLRA Table 4.3.4, and confirmed the following:
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| o The EAF screening methodology (i.e., sentinel location identification) is consistent with the description in the SLRA and includes identifying the location with the maximum screening environmentally-adjusted cumulative usage factor (CUFen) for each applicable material type, in each transient section.
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| o The EAF screening methodology (i.e., sentinel location identification) included criteria for a location of one material to bound a location of a differing material within a transient section and in a different transient section.
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| However, the staff found that sufficient information was not available to complete its review of Dominion Energys basis for its TLAA disposition of EAF; specifically, the criteria in the EAF screening methodology (i.e., sentinel location identification) used for a location of one material to bound a location of a differing material within a transient section and in a different transient section. In order to obtain the necessary information, the staff will consider issuing an RAI or the applicant will supplement its SLRA.
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| During the audit, the staff reviewed OpE associated with the TLAAs in SLRA Section 4.3 in conjunction with the applicants Fatigue Monitoring Program. As part the review of the Fatigue Monitoring Program, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects.
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| The staff also audited the description of the Metal Fatigue TLAAs provided in the UFSAR supplement. Specifically, the staff noted that the disposition of the TLAAs in SLRA Section 4.3 are not consistent with Appendix A of the SLRA (e.g., ASME Section III, Class 1 components and high energy line break). The staff will consider issuing an RAIs in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
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| SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment Summary of Information in the Application. SLRA Section 4.4, Environmental Qualification of Electric Equipment, discusses the thermal, radiation, and cyclical aging analyses for the plant
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| - 109 -
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| electrical and I&C equipment. Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii). To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the EQ of Electric Equipment TLAA. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date CR 1012598 Determine EQ Program Impact from Steris-Isomedix 03/08/2019 Radiation Dose Part 21 CR 1040813 Part 21 Evaluation for ASCO EQ SOVs Requires Revision 03/08/2019 of EQ Documentation CR 1044269 Limitorque MOV EQ QDR File Discrepancies Related to 03/08/2019 Beta Radiation CR 1163439 EQ Program Review Required for EPRI NP-1558 revision 01/06/2021 ETE-SLR-2019-2001 North Anna Subsequent License Renewal Project - Revision 0 Regulated Event Report - 10 CFR 54.4(a)(3)
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| Environmental Qualification CM-AA-EQ-10 Fleet EQ Program Description Revision 5 CM-NA-EQ-100 Environmental Qualification Program Implementation Revision 6 EE-0014 Determination of Applicability of 10 CFR 50.49 and Revision 2 Specification Requirements for 10 CFR 50.49 Equipment or Safety-Related Equipment Located in a Mild Environment EQ-0079 Electrical Equipment Environmental Qualification Design Revision 0 Basis for North Anna and Surry Power Stations ETE-SLR-2019-2303 North Anna Subsequent License Renewal Project - Aging Revision 1 Management Program Evaluation Report - Environmental Qualification of Electric Equipment CR 1163439 EQ Program Review Required for EPRI NP-1558 revision 01/06/2021 The staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). The staff notes that the licensee generated condition report CR 1163439 during the audit to evaluate whether the recent revision to the EPRI Report NP-1558 has any adverse effects on the qualification of electric equipment at NAPS (specifically related to the activation energy used to determine the qualification of components).
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA TLAA A3.4 Environmental Qualification of Electric Equipment, provided in the UFSAR supplement. The staff verified this description is
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| - 110 -
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| consistent with the description provided in the Section 4.4.3.2 and Table 4.4-2 of SRP-SLR Report.
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| SLRA TLAA Section 4.6 Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis and SLRA Section 3.5.2.2.1.5 Cumulative Fatigue Damage Summary of Information in the Application. SLRA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis, discusses the fatigue analysis for the containment liner plate. Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). The SLRA also states that NAPS has concrete containments and, therefore, fatigue of metal containment is not applicable. Further, the SLRA states there are no TLAAs for containment penetrations; however, SLRA Section 3.5.2.2.1.5 Cumulative Fatigue Damage states that an ASME Section III Code fatigue waiver analysis was performed for containment equipment hatch and cold penetrations components (CLB fatigue analysis does not exist; component materials listed in SLRA Table 4.6.1-1) to demonstrate that the aging effect does not require management.
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| To verify that Dominion Energy provided a basis to support its disposition of the containment liner plate TLAA, the staff audited the TLAA. The staff also audited documents supporting the further evaluation (FE) in SLRA Section 3.5.2.2.1.5 regarding fatigue waiver analysis of containment equipment hatch and cold penetrations (CLB fatigue analysis does not exist).
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis TLAA. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date Calculation 11715- Reactor Containment and Cold Penetrations Fatigue Revision 0, EA-14 Evaluation for 80-Year Plant Life, North Anna Unit 1 and Addendum 00D Unit 2 Calculation 11715- Reactor Containment Liner Analysis, NAPS Units 1 and 2 Revision 0 EA-14 Drawing Reactor Containment Schedule of Piping Penetrations - Revision 15 11715-FV-1A SH 1, NAPS Unit 1 ETE-SLR-2020- Summary of Fatigue Waiver - Pressure Retaining Revision 0 2334, Attachment 2 Components Subject to Cyclic Loading, But Have No CLB Fatigue Analysis For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
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| During the audit the staff made the following observations:
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| Based on the audit review of calculation 11715-EA-14, Revision 0, Addendum 00D, Reactor Containment Liner Analysis - Reactor Containment and Cold Penetrations Fatigue Evaluation for 80-Year Plant Life, North Anna Unit 1 and Unit 2, and ETE-SLR-2020-2334, Revision 0, Attachment 2 Summary of Fatigue Waiver - Pressure Retaining Components Subject to Cyclic Loading, But Have No CLB Fatigue Analysis, the staff verified that the six conditions for fatigue waiver in Subarticle N-415.1, Vessels Not Requiring Analysis for Cyclic Operation, of the ASME Code, Section III, 1968 Edition were evaluated and shown to be satisfied for (1) the containment liner plate (CLB fatigue analysis exists), and (2) the equipment hatch and containment cold penetration components CLB fatigue analysis does not exist; materials listed in SLRA Table 4.6.1-1 due to stress fluctuations caused by pressure, temperature and design earthquake cycles during an 80-year plant operating term. The staff further noted that Condition 5 Temperature Difference - Dissimilar Material was evaluated as not applicable for containment cold penetrations fabricated of dissimilar materials because DM welds will be monitored for cracking per Enhancement 1 to SLRA AMP B2.1.29, ASME Section XI, Subsection IWE.
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| The staff also audited the description of the SLRA Containment Liner Plate Fatigue Analysis TLAA provided in the UFSAR supplement. The staff verified this description is consistent with the example description provided in the SRP -SLR Table 4.6-1.
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| SLRA TLAA Section 4.7.1, Crane Load Cycle Limits Summary of Information in the Application. SLRA Section 4.7.1, Crane Load Cycle Limits, discusses the analyses of crane load cycles for containment polar cranes, fuel building movable platform, fuel building trolley, reactor containment annulus hoists, and auxiliary building monorails. Dominion Energy dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(i).
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| To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Crane Load Cycle Limits TLAA. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date N/A NRC Letter to VEPCO. SE NAPS U1 and U2, Control of 05/25/1984 Heavy Loads - Phase I CA 14938.76-S-1 VEPCO, NAPS U1 and U2, Design New Monorails to Revision 1 Clear Interferences N/A RHR Pump Monorails Inspection Summary 10/07/2020 (1-MH-CRN-47/48 and 2-MH-CRN-52/53)
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| WO 59048649301 59-01-MH-CRN47- HOIST, hook and crane load-tested, 3 03/06/2003 ton rated hook installed N/A RHR Pump Recent Monorail Lift History 12/09/2020 (WO 59048613901, WO 59045630801, WO 59048608301, WO 59046001601, WO 59045934501, WO 59038859201)
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| Document Title Revision / Date WO 59048613901 RHR pump corrective maintenance, use of 01-MH-CRN47 03/04/2003 monorail hoist (1-RH-P-1A)
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| WO 59045630801 RHR pump corrective maintenance, use of 01-MH-CRN47 09/16/2001 monorail hoist (1-RH-P-1A)
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| WO 59048608301 RHR pump corrective maintenance, use of 01-MH-CRN48 03/03/2003 monorail hoist (1-RH-P-1B)
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| WO 59046001601 RHR pump corrective maintenance, use of 02-MH-CRN42 11/12/2001 monorail hoist (2-RH-P-1A)
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| WO 59045934501 RHR pump corrective maintenance, use of 02-MH-CRN42 11/09/2001 monorail hoist (2-RH-P-1A)
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| WO 59038859201 RHR pump corrective maintenance, use of 02-MH-CRN42 06/01/1998 monorail hoist (2-RH-P-1B)
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| LR-1023/LR-2023 Technical Report License Renewal Project 06/04/2001 UFSAR Sections 9.1.4.4.5, 9.4.6.1, 9.6.4.7, Table 9.6-1, 18.3.5.1 Revision 55.03 ETE-SLR-2020-2316 NAPS SLR Project, AMP Evaluation Report - Inspection of Revision 2 Overhead Heavy Load and Light Load (Relate to Refueling) Handling Systems, Attachment 2, Crane Load Cycle Limits NUREG 0612 Control of Heavy Loads at Nuclear Power Plant 07/1980 VPAP-0809 NUREG-0612 Heavy Load Program Revision 10 0-MCM-1302-1 Moving Heavy Loads and Concrete Floor/Wall Plugs in the Revision 32 Aux Building Drawing 11715-FC- RHR Pump Monorail, Plan and Detail Sheet 1, VEPCO- 05/28/1993 16BK NAPS U1 Drawing 11715-FC- RHR Pump Monorail, Plan and Detail Sheet 2, VEPCO- 05/28/1993 16BL NAPS U1 Drawing 12050-FC- RHR Pump - Pipe SPRT, Plan and Details El 231-6, 06/12/1992 16AT-6 Interior Conc - Reactor Contmt, VEPCO-NAPS U2 NUREG 0612 Control of Heavy Loads at Nuclear Power Plant 07/1980 VPAP-0809 NUREG-0612 Heavy Load Program Revision 10 0-MCM-1302-1 Moving Heavy Loads and Concrete Floor/Wall Plugs in the Revision 32 Aux Building CE-0027 Technical Report: HILTI-KWIK-BOLT II (HKB II) - North Revision 1 Anna Power Station Units 1 & 2 CE-0319 Technical Report: HILTI-KWIK-BOLT 3 (KB 3) Expansion Revision 0 Anchors - North Anna and Surry Power Stations Units 1 & 2 HILTI Catalog - HILTI Anchoring Solutions for the Nuclear Industry 12/03/2020 App B During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observations:
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| The staff reviewed the RHR Pump Monorail Lift History dating back to 1998 and confirmed the paucity of lifts and that their use was solely for RHR pumps maintenance.
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| The staff reviewed HILTI Catalog - App B and confirmed that Dominion Energy post-installed HILTI anchor bolts meet the requirements of NQA-1 2000 and 10 CFR Appendix B.
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| The staff also reviewed Technical Reports CE-0027 and CE-0319 and confirmed, based in part on performed on-site tests, the HKB II and KB3 post-installed anchor adequacy to applied loads and loading conditions for different concrete mixtures.
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| The staff reviewed SLRA Table 4.7.1-2, Reactor Containment Polar Crane Operation, lift cycles and observed notable differences with those reported in sister plant Surry SLRA Table 4.7.1-1, Evaluation Summary of Crane Operation, (ADAMS Accession No. ML20052F523). The staff verified that increased lifts are due to more containment floor concrete hatches (for description see UFSAR Section 9.6.4.1 and Table 9.6-1) being lifted at NAPS and because the NAPS SLRA included more frequent lifts of lighter loads.
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| During the audit of the OpE associated with the TLAA, the staff independently searched the plant-specific ePortal database to identify any previously unknown or recurring aging effects.
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| The staff will evaluate, as necessary, the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA TLAA Section 4.7.1, Crane Load Cycle Limits provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR Section 4.7.2.2.
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| SLRA TLAA Section 4.7.2, Reactor Coolant Pump Flywheel Fatigue Crack Growth Summary of Information in the Application. SLRA Section 4.7.2, Reactor Coolant Pump Flywheel Fatigue Crack Growth Analyses, discusses the analyses for the RCP flywheel.
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| Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i). To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the RCP Flywheel Fatigue Crack Growth Analyses TLAA. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date PWROG-17011-NP-A Update for Subsequent License Renewal: Revision 2, WCAP-14535A, Topical Report on Reactor Coolant 10/2019 Pump Flywheel Inspection Elimination and WCAP-15666-A, Extension of Reactor Coolant Pump Motor Flywheel Examination (ADAMS Accession No. ML19318D189 NRC letter addressed to North Anna Power Station, Units 1 and 2 - Issuance 06/15/2005 Mr. David A. Christian of Amendments to Extend the Inspection Interval for Reactor Coolant Pump Flywheels (TAC NOS. MC4213 and MC4214) (ADAMS Accession No. ML051720359 During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the summary description of the TLAA for the RCP Flywheel Fatigue Crack Growth Analyses provided in the UFSAR supplement. The staff verified this summary description is consistent with the generic description provided in the SRP-SLR.
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| SLRA TLAA Section 4.7.3, Leak-Before-Break Summary of Information in the Application. SLRA Section 4.7.3, Leak-Before-Break, discusses the leak-before-break (LBB) analysis for the reactor coolant system primary loop piping. Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.
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| Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the LBB TLAA. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date LER 338-2012-001 Degraded Reactor Coolant System Piping Due To 05/18/2012 Primary Water Stress Corrosion Cracking CR 467649 Through-wall Cracks Were Observed on the Unit 1 B SG 03/24/2012 Hot Leg Weld CR 467719 Pre-overlay Manual UT Exam Failed to Identify 03/25/2012 Longitudinal Subsurface Flaws WCAP-11163 Technical Justification for Eliminating Large Primary Revision 2 Loop Pipe Rupture as the Structural Design Basis for North Anna Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 Years) Leak-Before-Break Evaluation
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| Document Title Revision / Date Supplement 1 to Additional Information in Support of the Technical January 1988 WCAP-11163, Justification for Eliminating Large Primary Loop Pipe Revision 0 Rupture as the Structural Design Basis for North Anna Units 1 and 2 WCAP-11163 Technical Basses for Eliminating Large Primary Loop Revision 0 Pipe Rupture as a Structural Design Basis for North Anna Units 1 & 2 SI Calculation LBB Evaluation for SG Inlet Nozzle Revision 3 1100226.303 SI Report Flaw Growth Results for North Anna Unit 1 for Revision 3 1800069.401 Subsequent License Renewal (SLR) - Steam Generator Inlet Nozzle [full structural] Weld Overlay (FSWOL)
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| SI Report Flaw Tolerance Results for North Anna Unit 1 for Revision 3 1800069.403 Subsequent License Renewal (SLR) - Steam Generator Inlet Nozzle full structural] Weld Overlay (FSWOL),
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| Supplemental Results for Stainless Steel Safe End Proposed Alternative North Anna Power Station Unit 1 Proposed Inservice 03/19/2020 N1-I5-NDE-003 Inspection Alternative N1-I5-NDE-003 Calculation Crack Growth Analysis for NAPS Unit 1 Steam Generator Revision 1 C-4520-00-02 Outlet Nozzles During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). The staff, however, found that additional information may be required to complete its review of Dominion Energys basis for the TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the SLRA LBB TLAA provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA LBB TLAA. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement description.
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| SLRA TLAA Section 4.7.4, Spent Fuel Pool Liner Fatigue Analysis Summary of Information in the Application. SLRA Section 4.7.4, Spent Fuel Pool Liner Fatigue Analysis, discusses the fatigue analysis for the spent fuel pool liner. Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Spent Fuel Pool Liner Fatigue Analysis TLAA. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED
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| Document Title Revision / Date Calculation 11715- Thermal Stress Analysis of Fuel Pool Liner - Fuel Pool Revision 0, NMB-282-FC, Liner Fatigue Evaluation for 80 Years Plant Life, NAPS Addendum 00B Addendum 00B Units 1 & 2 Calculation 11715- Thermal Stress Analysis of Fuel Pool Liner, NAPS Units Revision 0 NMB-282-FC 1&2 CE-1272 Analysis of Surry Fuel Pool Liner at 212 Degrees Revision 0 Fahrenheit During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. No significant plant-specific OpE associated with the SLRA TLAA Section 4.7.4, Spent Fuel Pool Fatigue Analysis, was noted by the staff during its review.
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| During the audit the staff made the following observations:
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| Based on the audit review of calculation, Calculation 11715-NMB-282-FC, Revision 0, Addendum 00B, Thermal Stress Analysis of Fuel Pool Liner - Fuel Pool Liner Fatigue Evaluation for 80 Years Plant Life, NAPS Units 1 & 2 and supporting referenced Calculation CE-1272, Revision 0, Analysis of Surry Fuel Pool Liner at 212 Degrees Fahrenheit, the staff noted that Dominion Energy calculated the limiting cumulative damage (or cumulative usage factor) due to fatigue effects of thermal cyclic loadings for the controlling component (i.e., plate-stiffener weld) of the SFP liner from the three design conditions described in the SLRA to be 0.75. This is less than the acceptance criterion of 1.0.
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| Based on review of Calculation CE-1272, Revision 0, the staff noted that the spent fuel pool liner configuration at NAPS and SPS are similar.
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| The staff also audited the description of the SLRA Spent Fuel Pool Liner Fatigue Analysis provided in the UFSAR supplement. The staff verified this description is consistent with the acceptance criteria provided in the SRP-SLR Section 4.7.2.2.
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| SLRA TLAA Section 4.7.7, Cracking Associated with Weld Deposited Cladding Summary of Information in the Application. SLRA Section 4.7.7, Cracking Associated with Weld Deposited Cladding, discusses the flaw tolerance analysis that evaluates the stability of subsurface cracks that potentially may be present in the RPV welds used to RPV cladding to the RPV shell. Dominion Energy dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
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| To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities.
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| During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Cracking Associated with Weld Deposited Cladding TLAA. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date PWROG-17031-NP-A Update for Subsequent License Renewal: Revision 1, WCAP-15338-A, A Review of Cracking Associated 05/2020 with Weld Deposited Cladding in Operating PWR Plants (ADAMS Accession No. ML20132A221)
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| PWROG-16031-P Implementation of WCAP-16168-NP-A, Revision 3, for Revision 0, (PROPRIETARY) North Anna Units 1 and 2 (Proprietary) 06/2016 WCAP-18503-P Resolution of North Anna Power Station Units 1 & 2 Revision 1, (PROPRIETARY) Time-Limited Aging Analyses for Subsequent License 07/2020 Renewal (Proprietary)
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| CN-SDA-II-18-007 Transient Basis for North Anna Units 1 and 2 80-Year Revision 1, (PROPRIETARY) Subsequent License Renewal TLAA Evaluations 04/2020 (Proprietary)
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| PWROG letter OG Transmittal of the Response to Request for Additional 08/29/2019 184, i.e., the Schrader Information, RAIs 1, 2 and 3 Associated with letter PWROG-17031-NP, Revision 1, Update for Subsequent License Renewal: WCAP-15338-A, 'A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants, PA-MSC-1497 (ADAMS Accession No. ML19253B327)
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| During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| During the audit the staff made the following observation:
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| SLRA Section 4.7.7 stated that the Excessive Feedwater Flow transient in the Schrader letter is not a transient at NAPS, Units 1 and 2. Dominion Energy described how four other transients in the Schrader letter were not applicable to NAPS, Units 1 and 2 by referring to a proprietary document that contains the 80-year transient basis for the units.
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| The staff also audited the summary description of the Cracking Associated with Weld Deposited Cladding TLAA provided in the UFSAR supplement. The staff verified this summary description is consistent with the generic description provided in the SRP-SLR.
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| SLRA TLAA Section 4.7.8, Steam Generator Tube Wear Evaluation Summary of Information in the Application. SLRA Section 4.7.8, Steam Generator Tube Wear Evaluation, discusses the wear analysis for the steam generator tubes. Dominion dispositioned
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| the TLAA in accordance with 10 CFR 54.21(c)(1)(iii). To verify that Dominion Energy provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the Steam Generator Tube Wear Evaluation TLAA. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date The Effect of an Update to 2968 MWt [megawatt-thermal]
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| CN-SGDA-02-23 NSSS [nuclear steam supply system] Power for North Revision 1 Anna Units 1 & 2 on Steam Generator Tube Wear Resolution of North Anna Power Station Units 1&2 WCAP-18503-NP Time-Limited Aging Analyses for Subsequent License 07/2020 Renewal During the audit of the TLAA, the staff verified that Dominion Energy has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
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| For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| The staff also audited the description of the Steam Generator Tube Wear Evaluation provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
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| AMR Item Not Associated with an AMP SLRA AMR FE 3.5.2.2.2.6 Reduction of Strength and Mechanical Properties of Concrete due to Irradiation Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:
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| SLRA Section 3.5.2.2.2.6, which describes Dominion Energys Further Evaluation of the aging effects of irradiation on the Concrete Biological Shield (CBS Wall or Primary Shield Wall) and the RV Support Steel Assembly. Based on the evaluation, the SLRA states that a plant-specific aging management program is not required to manage the effects of irradiation. This FE is associated with SLRA Table 3.5.1, Item 3.5.1-097.
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| Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the FE 3.5.2.2.2.6. The staff will document its review of this information in the SER.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date RV Support Steel Assembly CA 0199440 Inspect U2 NST Leakage at N43 Neutron Detector 09/30/2008 CR 0919944 Repair Strategy for U1 and U2 NST Leakages 02/28/2008 CR 109582 U2 NST Leakage - 10 to 12 drops per minute (dpm) at 09/15/2008 N43 Neutron Detector CA 164099 U2 NST Leakage - Inspect at N43 Neutron Detector 03/26/2010 during 2011 RFO CR 440432 U2 NST Leakage - CC leak, 10 dpm 08/30/2011 CA 212889 U2 NST Leakage - Inspect/trend leakage from N43 09/18/2011 detector at each RFO CR 513999 U2 NST Leakage - CC leak, 10 dpm 05/01/2013 CR 559195 U2 NST Leakage - CC leak, 20 dpm 09/19/2014 CR 1029353 U2 NST Leakage - CC leak, 10 dpm at N43 instrument 03/07/2016 tube CA 3026209 U2 NST Leakage - Inspect CC leak, 3 dpm at N43 03/11/2016 instrument tube. Evidence of wet/dry chromates CR 1077693 U2 NST Leakage - CC leak, 3 dpm at N43 instrument 09/11/2017 tube CA 3065626 CA to Engineering to track U2 RFO 26 NST bottom 09/12/2017 inspection CA 181398 Inspect U1 NST during 2012 Spring RFO, document and 10/12/2010 trend CR 440679 U1 NST - Post Seismic walkdown. Two dried chromate 08/31/2011 (inactive) leaks. Identified in 2001 for instrument tube flange 01-NM-FD-190 and 2004 for Neutron detector N43 CR 466001 U1 NST - Two inactive leaks (see CR440679) 03/13/2012 CA 3040540 Inspect Unit 1 NST during the 2018 Spring RFO (see 09/21/2016 CA 3163398)
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| CA 3163398 STARTUP-Inspect Unit 1 NST during the 2019 Fall RFO 10/03/2019 (Follow-on from CA 3040540)
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| N/A Unit 1 Ops Logs for Filing NST, 2015-2020 12/14/2020 N/A Unit 2 Ops Logs for Filing NST, 2015-2020 12/17/2020 N/A U1NST - Leakage Trend Data at NFD-190 and N-43 09/03/2020 Detector Locations N/A U2NST - Leakage Trend Data at N43* Detector Location 09/03/2020 N/A Unit 1 and Unit 2 Sampling for 10 Years - (OpE Water 09/03/2020 Chemistry)
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| Document Title Revision / Date CBS Wall EPRI Technical Irradiation Damage of the Concrete Biological Shield that May 2018 Report 3002013051 Utilizes a Neutron Shield Tank - Basis for Concrete Biological Shield Wall for Aging Management Drawing 11715-FC- Foundation Mat Details EL 214 5 SH Reactor Revision 12 15A-12 Containment, NAPS Unit 1 Drawing 11715-FC- Plan and Details EL 211 11 SH Interior Concrete Revision 20 16A Reactor Containment, NAPS Unit 1 Drawing 11715-FC- Primary Shield Wall SH Interior Concrete Reactor Revision 4 16C-4 Containment, NAPS Unit 1 Drawing 11715-FC- Plan and Details EL 242 6 SH Interior Concrete Revision 11 16F Reactor Containment, NAPS Unit 1 Drawing 11715-FC- Plan and Details EL 262 10 SH Interior Concrete Revision 20 16M Reactor Containment, NAPS Unit 1 LTR-REA-20-2 North Anna Unit 1 and Unit 2 Reactor Cavity Concrete Revision 0, Neutron Fluence and Gamma Dose (Westinghouse 04/02/2020 Proprietary Class 2)
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| RV Support Steel Assembly UFSAR 3.2.1, 3.8.2, 5.5.9, 9.2.2 Revision 55.03 Drawing 11715-FV- Reactor Neutron Shield Tank Assembly, North Anna Revision 5 6A-5 Power Station Drawing 11715-FV- Reactor Neutron Shield Tank SH-1, North Anna Power Revision 5 6B Station Drawing 11715-FV- Reactor Neutron Shield Tank SH-2, North Anna Power Revision 3 6C-3 Station Drawing 11715-FV- Reactor Neutron Shield Tank SH-3, North Anna Power Revision 6 6D-6 Station Drawing 11715-FV- Reactor Neutron Shield Tank SH-4, North Anna Power Revision 6 6E-6 Station Drawing 11715-FV- Reactor Neutron Shield Tank SH-5, North Anna Power Revision 4 6F-4 Station Drawing 11715-FV- Reactor Neutron Shield Tank SH-6, North Anna Power Revision 4 6G-4 Station Drawing 11715-FV- Reactor Neutron Shield Tank Lead Shielding SH-1, North Revision 3 6H-3 Anna Power Station Drawing 11715-FV- Reactor Neutron Shield Tank Lead Shielding SH-2, North Revision 1 6J-1 Anna Power Station Drawing 11715-FV- Reactor Neutron Shield Tank SH-7, North Anna Power Revision 5 6K-5 Station Drawing 11715-FV- Reactor Neutron Shield Tank SH-8, North Anna Power Revision 5 6L-5 Station Drawing 11715-FV- Reactor Neutron Shield Tank Lead Shielding SH-3, North Revision 3 6M-3 Anna Power Station LTR-REA-20-3 North Anna Unit 1 and Unit 2 Neutron Shield Tank (NST) Revision 0, Neutron Fluence (Westinghouse Proprietary Class 2) 04/02/2020
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| Document Title Revision / Date ETE-SLR-2019-2202 Review of Neutron Shield Tank Configuration for NAPS Revision 0 Units 1 & 2 Reactor Vessel Supports 02/07/2020 ETE-SLR-2019-2203 Review of Loads on Neutron Shield Tank for NAPS Revision 0 Units 1 & 2 Reactor Vessel Supports 02/07/2020 ETE-SLR-2020-2204 Assessment of Radiation Effects on Reactor Vessel Revision 0 Supports for NAPS Units 1 & 2 04/22/2020 ETE-NA-2019-0018 Evaluate Acceptable Maintenance Threshold for Neutron Revision 0 Shield Tank Leakage (references staff reviewed OpE) 07/17/2019 ET-N-07-0008 Justification for Increasing the Chloride and Fluoride Revision 1 Concentration in Component Cooling and Neutron Shield 06/04/2009 Tank Cooling EPRI 3002000590 Closed Cooling Water Chemistry Guideline Revision 2 CH-99.700 Units 1 & 2, Closed Cooling Water Systems Chemistry Revision 0 Specifications and Action Levels CH-99.701 Units 1 & 2, Closed Cooling Water Systems Chemistry Revision 0 Strategic Plan CY-AA-AUX-301 Closed Cooling Water Chemistry Revision 3 ETE-SLR-2020-2418 North Anna Subsequent License Renewal Project - Revision 0 Position Paper - Lubrite Aging Effects due to Irradiation J.O.Nos. 11715 / Fabrication of NST and Lead Shielding for NAPS, 1975 02/18/1971 12050 NAS-43 Extension CE-1634 Calculation - The Effect of Reactor Pressure Vessel Revision 1 (RPV) Head Replacement on the RPV Support System 03/24/2003 (Sliding Foot Assemblies and NST), NAP Units 1 and 2 CE-1634-00A Addendum to calculation - The Effect of Reactor 03/31/2015 Pressure Vessel (RPV) Head Replacement on the RPV Support System (Sliding Foot Assemblies and NST),
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| NAP Units 1 and 2 For the audit of the operating experience program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff will evaluate the identified plant-specific OpE in the SER.
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| Concrete Biological Shield Wall During the audit the staff made the following observations:
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| The staff reviewed LTR-REA-20-2 and verified the maximum fluence and maximum gamma surface dose estimates and their locations at the CBS wall surface for NAPS Unit 1 and Unit 2 reported in SLRA Section 3.5.2.2.2.6.
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| RV Support Steel Assembly During the audit the staff made the following observations during its review:
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| (LTR-REA-20-3) Radiation exposure values of the NAPS Units 1 and 2 NSTs adjacent to the RV core region, at the NST vessel side (inner surface) at RV nozzle azimuthal angles and top for 72 FPY are as reported in SLRA Section 3.5.2.2.2.6.
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| (ETE-SLR-2019-2203) The NAPS NST stresses are calculated based on the design loads and at critical locations, consistent with the methodology detailed in Stone & Webster 15253.28-NM(B)-318, Revision 0, as reported in NAPS SLRA Section 3.5.2.2.2.6. The staff also confirmed that the methodology was previously used to evaluate the nearly identical/structurally equivalent SPS NSTs, as discussed in Final SPS SLR SER (ADAMS Accession No. ML20052F523).
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| (J.O. Nos. 11715/12050, NAS-43 (see also DWG 11715-FV-6D for NAPS Unit 1)) The material for the RV support sliding foot assemblies are fabricated from AISI 4330-mod forgings with sliding shoe surfaces coated with high quality Lubrite, as reported in SLRA Section 3.5.2.2.2.6.
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| (ETE-SLR-2020-2418) Consistent with staffs evaluation of Lubrite coating on SPS sliding shoe surfaces (see Final SPS SLR SER, ADAMS Accession No. ML20052F523), the effects of aging due to radiation on NAPS Lubrite coated sliding shoe surfaces are similar and considered insignificant as noted in SLRA Section 3.5.2.2.2.6.
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| (ETE-SLR-2020-2418) Following the 2011 earthquake, inspections performed on NAPS, Units 1 and 2 RV sliding foot assemblies yielded satisfactory results. The inspection for the Unit 1 Loop B cold leg RV sliding foot assembly (requested by NRC inspectors) resulted in no indications or cracking (see also CR 448934, On-Site Direct Observations section of this report). The inspection for the Unit 2 RV sliding foot assemblies found one sliding foot to have no measurable gap and minor rub marks on the adjacent block face (see also CR 448737, On-Site Direct Observations section of this audit reports).
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| (ETE-SLR-2020-2204) A discrepancy was noted in the discussion regarding embrittlement of the NST steel plates with that in SLRA Section 3.5.2.2.2.6. Although the SLRA Section 3.5.2.2.2.6 discusses the initial properties of the NST plates, namely the nil-ductility temperature values (-40 °F at the inner shell of the NST and -20 °F or better at other locations of the NST), the staff did not see such discussion in ETE-SLR-2020-2204.
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| Similarly, there were no discussions on embrittlement of welds and of associated heat affected zones of NST steel plates. During the audit, the staff requested that Dominion Energy clarify embrittlement of NAPS NST weldments and associated heat affected zones by referring to fracture toughness and residual stress guidance in NUREG-1509. The staff intends to have Dominion Energy clarify through an RAI whether the fracture mechanics evaluation of the NAPS NST plates bounds those of the weldments and heat affected zones. The staff reviewed (in ETE-SLR-2019-2202) the table of configuration comparisons for NAPS, Units 1 and 2 and Surry, Units 1 and 2 NSTs and observed that weldments, heat affected zones, thickness and material of NST plates, as well as welding electrodes used, and heat treatments performed between NAPS and SPS are nearly identical. The staff also noted that the fabrication specification and assembly drawings of NSTs for NAPS, Units 1 and 2 (specification NAS-43 and drawing 11715-FV-6A-5) show ample evidence that all weldments of the NSTs were radiographed (i.e., inspected for indications).
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| (CE-1634) Operating condition loads include operating basis earthquake, thermal expansion, friction, steady state hydraulic loads, and dead weight loads. The staff also noted that a conservatively assumed RV replacement head weight used in calculations slightly increases the original design dead load on each of the six RV sliding foot assemblies. Operating loads added to the design basis earthquake (DBE) seismic forces and to loss of coolant loads due to primary reactor coolant loop (RCL) line break or those of branch lines breaks, however, could lead to stresses at RV sliding foot assemblies exceeding material yield strengths at proper temperatures. The staff noted that when loads due to main RCL ruptures are eliminated the RV support system design has significant margins. The lowest margins occur in socket plate cap-screws and on the nozzle pad internal thread shear capacity. The staff will consider requesting clarifications as noted in suggested RAI(s) (a) and (b) included below.
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| The staff requested clarifications regarding Table 1 on page 3-779 of the SLRA. The staff asked Dominion Energy to: (a) confirm a minor typographical error in Table 1 on page 3-779 of the SLRA: The critical stress for the Case 2 NST inner surface flaw shown in the table should be 30 ksi instead of 36 ksi per page 18 of 24 of ETE-SLR-2020-2204; (b) clarify that the inner NST surface flaw analyzed in Table 1 is for a flaw that is quarter-thickness (1/4T) deep; and (c) confirm the staffs understanding of how the fracture toughness (KIC) vs stress plots in Figures 1 through 4 of ETE-SLR-2020-2204 were determined and that the critical stress in Table 1 on page 3-779 of the SLRA came from these plots. Dominion Energy (a) confirmed the minor typographical in Table 1 on page 3-779 of the SLRA identified by the staff and stated it will be corrected in a planned SLRA supplement; (b) noted that the inner surface flaw analyzed in Table 1 is for a flaw that has a depth of 1/4T; and (c) clarified that the stress in Figures 1 through 4 of ETE-SLR-2020-2204 was back calculated from the applied stress intensity factor (K) set equal to KIC and that the critical stress in Table 1 on page 3-779 of the SLRA came from these plots. Based on the above observations in ETE-SLR-2020-2204, the staff plans to request confirmation on the docket for NAPS statements (b) and (c) made above.
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| The staff noted the fracture mechanics evaluation of SLRA Section 3.5.2.2.2.6 discusses two cases. Case 1 is for materials having a minimum yield strength of 32 ksi and Case 2 for those of 52 ksi. Procedure ETE-SLR-2020-2204 includes a table with two additional cases, Case 3 (for materials of 42.9 ksi yield stress) and Case 4 (for those with 62.9 ksi yield stress). The staff noted that 42.9 ksi is the unirradiated yield stress of the NSTs per page 18 of ETE-SLR-2020-2204. The staff observed that the difference in critical stress values for Cases 2 and 4 in ETE-SLR-2020-2204 is small. Based on the above observations in ETE-SLR-2020-2204, the staff requests Dominion Energy to confirm that Case 2 bounds Case 3, and that Case 4 was analyzed as a quality check for the effect of higher levels of irradiation (reflected by the 62.9 ksi yield stress) on the values of critical stress and that Cases 3 and 4 need not be included in SLRA Section 3.5.2.2.2.6.
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| (ETE-NA-2019-0018) Dominion Energy monitors Unit 1 and Unit 2 at the main control room daily and trends NST leakages at each refueling outage. Leakage in Unit 1 NST is at the neutron flux detector (excore) 1-NMD-NFD-190 and in Unit 2 is at the power range detector 2-NI-NE-43A (see also reviewed document NRCODP-60-NA in Direct Observations). The 20 dpm of NAPS is compared to the 70 dpm of Surry and observes that no significant degrading trend was observed over the last 25 years.
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| (ETE-N-07-008) Concentrations for chromates were exceedingly high and beyond the Action Levels promulgated in CH-99.700 but deemed acceptable per reviewed ET-N
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| 0008. The staff also noted that CH-99.700 for corrective actions refers to EPRI Closed Cooling Water Guideline, Revision 2 when limits of tracked parameters are exceeded, with an allowed deviation for chromates as discussed in CH-99.701.
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| (Unit 1 and Unit 2 Sampling for 10 years) In addition to high chromate concentrations, the Unit 1 NST fluid has an elevated conductivity as well. EPRI Closed Cooling Water Guideline, Revision 2, identifies fluid conductivity as a diagnostic parameter for a corrosive environment. It recommends a conductivity value ( 2 µS/cm) far less than those being reported for the NAPS NST Unit 1 fluid. In addition, for systems maintaining adequate inhibitors, pH levels, and microbiological control, the EPRI Report suggest loss of material values from good to poor. The staff will request clarifications as noted in suggested RAI(s)
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| (c) included below.
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| Direct Observations of Areas, Equipment Conditions, and Configurations Audit Activities. During its audit, the staff performed direct observations of NAPS using photographs and marked-up drawings indicating areas of NST leakage and of sliding foot assembly photos (included in the below CRs, summarized in part in item #5 of OpE Summary of SLRA Section B2.1.31). The staff interviewed Dominion Energys staff, which led Dominion Energy to place additional documentation on the ePortal for NST leakage and sliding foot assemblies. The table below lists relevant audit documents that the staff reviewed with the applicant in detail.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date NRCODP-60-NA Neutron Shield Tank Details, Figure 60-1, NA (Leakage) 12/11/2020 NRCODP-60-NA Neutron Shield Tank Details, Figure 60-2, NA (Leakage) 12/11/2020 CR 448934 NDE Exams of Rx vessel, U1 sliding foot. The 10/20/2011 augmented CR includes BOP-VT-11-039, Visual Exam of Equipment and Components (VT-1), and BOP-MT-11081, Magnetic Particle Examination, applicable plant-specific procedures, photos and results of examinations CR 448737 VT-3 inspection of U2 Rx Vessel Hot Leg Sliding Foot, 10/19/2011 rub marks identified on sliding foot vertical face component. Photos, sketches and results of examinations are included The staff made the following observation(s) during the audit:
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| The referenced above (and in SLRA AMP B2.1.31 Audit Report) CR448934 discusses details of inspection for a potential crack in the Unit 1 Loop B cold leg reactor vessel sliding foot following the 2011 earthquake. The staff requested that Dominion Energy confirm that inspections performed on the subject RV sliding foot through VT-1 and magnetic particle examinations in 2011 (as noted in the CR) showed no evidence of surface indications or cracking.
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| The referenced above (and in SLRA AMP B2.1.31 Audit Report) CR448737 discusses post 2011 earthquake inspections performed for the Unit 2 RV sliding foot assemblies.
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| The report states that one sliding foot had no measurable gap and minor rub marks with adjacent block face.
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| The staff will consider issuing RAIs based on the staffs review of on-site documentation. The staff will document its evaluation of these potential RAI(s) in the SER.
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| SLRA AMR FE 3.6.2.2.3, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following four AMR items discussed in SLRA 3.6.2.2.3 FE section:
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| SLRA Table 3.6.1-004, transmission conductors composed of aluminum, and steel exposed to air-outdoor SLRA Table 3.6.1-005, transmission connectors composed of aluminum, and steel exposed to air-outdoor SLRA Table 3.6.1-006, switchyard bus and connections composed of aluminum, copper, bronze, stainless steel, and galvanized steel exposed to air-outdoor SLRA Table 3.6.1-007, transmission conductors composed of aluminum, and steel exposed to air-outdoor Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the review of these items. These documents were provided by Dominion Energy.
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| RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ETE-SLR-2020-2606 North Anna Subsequent License Renewal Project - Revision 1 Further Evaluation Recommended Report - SRP Section 3.6 Electrical, Instrumentation and Controls 1211034Z.DGN Operating One Line Diagram - Substation North Anna 04/06/1994 34.5 kV ETE-SLR-2020-2106 North Anna Subsequent License Renewal Project - Revision 0 Integrated Plant Assessment Report - Electrical Components N/A Dominion Overhead Construction Manual April 2017 Specification Sheet Southwire 1272 kcmil Overheated Rope-Lay Conductor 03/03/2010
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| During the audit the staff made the following observations:
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| The staff reviewed Dominion Energys construction overhead manual referenced above and noted that washers and lock washers are used in construction of 34.5 kV transmission line components to maintain connection torque requirements and prevent loss of preload. Dominion Energy will provide a supplement to the SLRA, stating the use of lock washers. This input will be discussed in SER Section 3.6.2.2.3.
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| The staff noted the use of Rope-Lay conductor on the in-scope overhead 34.5 kV system depicted in drawing 1211034Z.DGN referenced above. The staff reviewed the specification sheet for Rope-Lay referenced above and verified that this transmission conductor is composed of aluminum only with no steel alloy components.
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| The staff reviewed Dominion Energys FE in SLRA Section 3.6.2.2.3, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections. This input will be discussed in SER Section 3.6.2.2.3.
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| : 3. Supplement to the SLRA On February 4, 2021, Dominion Energy voluntary submitted a supplement to the SLRA (ADAMS Accession No. ML21035A303) on a total of 35 topics resulting from the discussions held during the in-office regulatory audit The list of topics supplemented is provided in Attachment 2 to this audit report.
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| : 4. Applicant Personnel Contacted During Audit Name Affiliation Paul Aitken Dominion Energy Noah Beal Dominion Energy Eric Blocher Dominion Energy Ronald Burner Dominion Energy Michael Carter Dominion Energy Charles Tomes Dominion Energy Pratt Cherry Dominion Energy Brian Derreberry Dominion Energy John Disosway Dominion Energy Richard Eagan Dominion Energy Addison Hall Dominion Energy Craig Heah Dominion Energy James Hester Dominion Energy Delbert Horn Dominion Energy Dan Madden Dominion Energy Patrick Nelson Dominion Energy Mark Pelligrino Dominion Energy Tom Snow Dominion Energy Ray Stacks Dominion Energy John M. Thomas Dominion Energy Gregory Travers Dominion Energy James Zaborowski Dominion Energy Yue Zou Dominion Energy Jim Axeline Structural Integrity Tim Griesbach Structural Integrity Christopher Lohse Structural Integrity Eric Johnson Westinghouse Anees Udyawar Westinghouse
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| : 5. Exit Meeting An exit meeting was held with the applicant on January 8, 2021, to discuss the results of the in-office regulatory audit. The staff is considering the issuance of RAIs and RCIs to support the completion of the staffs SLRA review.
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| Audit Questions Provided to the Virginia Electric and Power Company During the In-Office Regulatory Audit SLRA Section 2.3.3.35 - Scoping and Screening for Heating & Ventilation
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| # SLRA Section SLRA Page Question / Issue 1 Ventilation Stack A SLRA Drawing 11715-SLRB-006A Sheet 3 (Coordinate F-3) displays Vent Stack A as being subject to aging management review (AMR). However, SLRA Table 2.3.3-35 Heating & Ventilation does not list the Component Type Stack as being subject to AMR.
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| The staff request additional information about the discrepancy between the SLRA drawing and the cited SLRA Table.
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| SLRA Section 2.3.3.35 - Scoping and Screening for Heating & Ventilation /Containment Ventilation
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| # SLRA Section SLRA Page Question / Issue 1 SLRA Drawing 11715-SLRB-006A Sheet 1 displays inside Containment and Control Rod Drive Cooling Coil Housings (e.g., 1-HV-D-2A/B/C; 1-HV-E-6A/B/C) as fulfilling a Safety-Related a (1) function. The connecting ductwork is not depicted as within scope of license renewal.
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| The staff request additional information:
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| Since these Containment Cooling Coil Housings are safety-related, how is the non-safety-related ductwork isolated from these housings such that a Structural Integrity intended function is not warranted?
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| SLRA Section 2.3.3.40 - Scoping and Screening for Emergency Diesel Generator System/Starting Air
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| # SLRA Section SLRA Page Question / Issue 1 Updated Final Safety Analysis Report (UFSAR)
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| Section 9.5.6 Diesel Generator Starting System reads in part:
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| : 8. Vent Valve This valve, which is arranged to open when the solenoid start valves are closed and vice versa, is provided to vent the air from the engine air distributor when the air-start solenoid valves are closed. This prevents wear on the air-start distributor cam.
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| Attachment 1 to Enclosure
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| SLRA Section 2.3.3.40 - Scoping and Screening for Emergency Diesel Generator System/Starting Air
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| # SLRA Section SLRA Page Question / Issue SLRA Drawing 11715-SLRB-107A Sheet 1 (Coordinate E-6) displays the vent line from Vent Valve 1EG-SOV-601HA as being capped and not open to the atmosphere.
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| SLRA Drawing 11715-SLRB-107A Sheet 3 (Coordinate E-6) displays the vent line from Vent Valve 1EG-SOV-601JA as being capped and not open to the atmosphere.
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| The other Unit 2 EDG Starting Air system SLRA drawings depict the corollary vent lines as being uncapped and in agreement with the UFSAR.
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| The staff request additional information about the discrepancy between the UFSAR and the cited SLRA drawings.
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| SLRA Section 2.4.1.29 - Scoping and Screening for Service Building
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| # SLRA Section SLRA Page Question / Issue 1 Service Building Battery Room Ventilation SLRA Drawing 11715-SLRB-044F Sheet 1 (Coordinate A-3/4) displays both Supply and Exhaust Fans as fulfilling an a (1) function. However, SLRA Table 2.3.3-35 Heating & Ventilation only lists Fan housing (battery room exhaust) as being subject to AMR.
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| 2 Service Building A/C Chiller Room SLRA Drawing 11715-SLRB-044F Sheet 1 (Coordinate D-3/4) displays a missile screen protecting the exhaust fan housing. However, SLRA Table 2.3.3-35 Heating &
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| Ventilation does not list the Component Type Missile Screen as being subject to AMR.
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| The staff request additional information about these discrepancies between the SLRA drawing and the cited SLRA Table.
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| SLRA Section 2.4.1.3 - Scoping and Screening for Auxiliary Building Design Basis
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| # SLRA Section SLRA Page Question / Issue 1 UFSAR Section 9.4.2 Auxiliary Building Design Basis reads in part; The auxiliary building central area exhaust system fan discharge ducts are seismically supported from the three area fans to preclude crimping of the exhaust system within the auxiliary building, and allow air flow through the duct system to a point exterior to the building. At a point in the central area exhaust exterior to the auxiliary building envelope, an automatic pressure relief opening provides an exit point for the central area exhaust air. In addition, a manually actuated relief opening can be actuated by the operator. These relief openings provide a
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| SLRA Section 2.4.1.3 - Scoping and Screening for Auxiliary Building Design Basis
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| # SLRA Section SLRA Page Question / Issue means of restoring ventilation to the charging pumps/high head safety injection pumps after a seismic event.
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| SLRA Drawing 11715-SLRB-006A Sheet 3 displays several Air Operated Dampers (e.g., 2-HV-AOD-400 @
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| Coordinate D-4) where the damper bodies (i.e., pivoted flapper with seat) are not shown as being subject to AMR.
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| However, the actuation of these AODs releases air to the confines of the Auxiliary Building and not to the exterior of the auxiliary building envelope.
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| The staff requests clarification of the purpose of the multiple subject AODs displayed on SLRA Drawing 11715-SLRB-006A Sheet 3 and how the intent of the above UFSAR passage is satisfied.
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| 2 UFSAR Section 9.4.2 Auxiliary Building Design Basis reads in part; The auxiliary building central area exhaust system fan discharge ducts are seismically supported from the three area fans to preclude crimping of the exhaust system within the auxiliary building, and allow air flow through the duct system to a point exterior to the building. At a point in the central area exhaust exterior to the auxiliary building envelope, an automatic pressure relief opening provides an exit point for the central area exhaust air. In addition, a manually actuated relief opening can be actuated by the operator. These relief openings provide a means of restoring ventilation to the charging pumps/high head safety injection pumps after a seismic event.
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| SLRA Drawing 11715-SLRB-006A Sheet 3 displays several Air Operated Dampers (e.g., 2-HV-AOD-400 @
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| Coordinate D-4) where the damper bodies (i.e., pivoted flapper with seat) are not shown as being subject to AMR.
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| However, the actuation of these AODs releases air to the confines of the Auxiliary Building and not to the exterior of the auxiliary building envelope.
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| The staff requests clarification of the purpose of the multiple subject AODs displayed on SLRA Drawing 11715-SLRB-006A Sheet 3 and how the intent of the above UFSAR passage is satisfied.
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| SLRA Section 2.2 - Plant-Level Scoping Results- Scoping of Structures
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| # SLRA Section SLRA Page Question / Issue 1 SLRA Table 2.2-1 SLRA pdf 107 SLRA Table 2.2-1 notes that the service water reservoir and UFSAR and 2577 of 5803 horizontal drains and piezometers are not in-scope. The Section 3.8.4.6 service water pumphouse is in-scope and UFSAR Section 3.8.4.6 seems to indicate the horizontal drains are installed to control settlement of the pumphouse and are monitored on a 6-month frequency. If these drains are being monitored to control settlement of an in-scope
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| SLRA Section 2.2 - Plant-Level Scoping Results- Scoping of Structures
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| # SLRA Section SLRA Page Question / Issue structure, it is not clear why they are not in-scope for license renewal (LR) and subject to AMR.
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| SLRA Section 2.3.3.42 - Scoping for Fire Protection
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| # SLRA Section SLRA Page Question / Issue 1 2.3.3.42
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| ==Background:==
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| For NAPS, the staff reviewed the subsequent license renewal application (SLRA), NUREG-1766, Safety Evaluation Report Related to License Renewal of North Anna Power Station, Units 1 and 2, and Surry Power Station, Units 1 and 2, December 2002, ADAMS Package Accession No. ML20052F523; SLRA drawings, UFSAR Section 9.5.1, Fire Protection System and fire protection current licensing basis documents listed NAPS license condition 2.C.4.
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| Issue:
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| The following boundary drawings show the fire protection systems/components as not within the scope of license renewal (i.e., not colored in blue):
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| SLRA Drawing Systems/Components Location 11715-SLRB-104B Sh. 2 Low-Pressure Carbon Dioxide A4 to E4 Drawing 11715-SLRB-104C Sh. 4 Low-Pressure Carbon Dioxide A5 to E5 Request:
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| Verify whether the fire protection systems/components listed above are within the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an AMR in accordance with 10 CFR 54.21(a)(1), because these components appear to be necessary to meet the requirements for 10 CFR 50.48. If they are not within the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.
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| 2 2.3.3.42
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| ==Background:==
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| For NAPS, the staff reviewed the SLRA, NUREG-1766, Safety Evaluation Report Related to License Renewal of North Anna Power Station, Units 1 and 2, and Surry Power Station, Units 1 and 2, December 2002, ADAMS Accession No. ML20052F523; SLRA drawings, UFSAR, Section 9.5.1, Fire Protection System and fire protection current licensing basis documents listed NAPS license condition 2.C.4.
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| SLRA Drawing 11715-SLRB-41B Sh. 1 shows that the diesel-driven fire protection pump engine coolant heat exchanger and some associated piping as not being highlighted and consequently not credited by the current licensing basis for performing an intended function as
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| SLRA Section 2.3.3.42 - Scoping for Fire Protection
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| # SLRA Section SLRA Page Question / Issue defined by 10 CFR 54.4(a)(1), (a)(2),or (a)(3) (based on SLRA Drawing SLR Legend, Subsequent License Renewal Drawing Legend). The associated note says that the heat exchanger is part of a skid-mounted active assembly (engine) and therefore not subject to an AMR.
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| Similarly, SLRA Section 2.3.3-42 states, Diesel-driven fire pump engine components within the skid boundaries are part of the active assembly and are not subject to aging management review SLRA Drawing 11715-SLRB-41B SH 1 also shows that the air compressor and associated components between the compressor and hydropneumatic tank are not subject to an AMR. The associated note says that the components are skid-mounted and considered as an active assembly and therefore not subject to an AMR.
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| However, unlike the diesel engine above, SLRA Section 2.3.3-42 does not include any discussion about the air compressor assembly.
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| The staff notes that, for initial license renewal application (LRA) ADAMS Accession No. ML011500480, Table 3.3.9-1, Fire Protection, included AMR items for Diesel Fire Pump Radiator to manage loss of material and heat transfer degradation; and for Compressor Casing to manage loss of material. However, comparable items are not shown in SLRA Table 3.3.2 42, Fire Protection, for either component. The staff also notes that the industrys consideration of complex assemblies, as provided in Nuclear Energy Institute (NEI) 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, (subsequently endorsed by the U.S. Nuclear Regulatory Commission (NRC)) has not changed since initially being issued in 1996.
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| Issue:
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| The statements in SLRA Section 2.3.3-42 and on the above cited drawing indicate that the diesel engine coolant heat exchanger and associated components are within the scope of license renewal but are not subject to an AMR. However, the explanation of the highlighting on the SLR Legend appears to say that un-highlighted components are not credited by the current licensing bases for performing an intended function and therefore would not be within the scope of license renewal.
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| Based on the NAPS, initial LRA, the diesel-driven fire protection pump engine coolant heat exchanger was screened-in consistent with the longstanding guidance for diesel engine jacket water heat exchangers. However, the screening of this component for the SLRA does not follow the current guidance in NUREG 2192, Standard
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| SLRA Section 2.3.3.42 - Scoping for Fire Protection
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| # SLRA Section SLRA Page Question / Issue Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, July 2017, ADAMS Accession No. ML17188A158, Table 2.3-2, Examples of Mechanical Components Screening and Basis for Disposition and NEI 95-10. Similarly, the SLRA screening of the passive portions for the fire protection air compressor were changed from the initial license renewal application. The staff notes that screening can be inconsistent with the guidance if justification is provided with a reasonable basis for the inconsistency.
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| Request:
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| (1) Confirm that the fire protection diesel-driven pump engine coolant heat exchanger and associated components are within the scope of license renewal.
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| If not, provide the bases to show that the diesel engine can perform its current licensing basis intended function without the heat exchanger or associated piping and components. If needed, provide clarification to the explanation of the blue highlighting on Drawing SLR Legend.
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| (2) Given that the existing testing and monitoring of the active assembly (i.e., skid-mounted fire protection diesel-driven pump engine components) were unable to identify degradation of the engine coolant heat exchanger prior to a functional failure:
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| (a) discuss what changes were made to the testing and monitoring in order to demonstrate that the effects of aging will be adequately managed, comparable to that required by 10 CFR 54.21(a)(3).
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| (b) because the functional failure analysis noted that the zero run-to-failure criteria was too restrictive, discuss whether the criteria for the assembly has been changed, (c) because the testing and monitoring activities of the assembly are not part of an AMR, describe how these activities will be annotated to ensure that the effects of aging will continue to be managed during the subsequent period of extended operation.
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| (3) For the air compressor assembly associated with the fire protection system hydropneumatic tank:
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| (a) provide information to demonstrate that the specific testing and monitoring performed on the assembly are sufficient to identify degradation of the associated passive components, comparable to that required by 10 CFR 54.21(a)(3).
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| (b) because the testing and monitoring activities of the assembly are not part of an AMR, describe how these activities will be annotated to ensure that the effects of aging will continue to be
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| SLRA Section 2.3.3.42 - Scoping for Fire Protection
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| # SLRA Section SLRA Page Question / Issue managed during the subsequent period of extended operation.
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| SLRA Section 3.5.2.2.1.1 - Concrete
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| # SLRA Section SLRA Page Question / Issue 1 3.5.2.2.1.1 3-761 SLRA Section 3.5.2.2.1.1 and Table 1 item 3.5.1-042 relate to loss of material and cracking due to freeze-thaw with associated further evaluation (FE), which states that aging effects due to freeze-thaw are not applicable.
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| However, NAPS is located in a region where weathering conditions are considered severe, as defined in American Society for Testing and Materials (ASTM) C-33. SLRA Section 3.5.2.2.1.1 states that reinforced concrete structures that were constructed during initial construction, excluding concrete structures located in the Switchyard, used an air-entraining agent in an amount sufficient to entrain an air content of three to five percent.
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| Based on NUREG-2192, Rev. 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, a plant-specific program is not required if documented evidence confirms that the existing concrete had air content of 3 percent to 8 percent and subsequent inspection did not exhibit degradation related to freeze-thaw. It is not clear what is the air content used in concrete mix design in concrete structures located in the Switchyard and if a plant-specific program is required for the concrete structures located in the Switchyard.
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| 2 Table 3.5.1 3-791 Table 1 items 3.5.1-047 and 3.5.1-051 relate to increase 3-792 in porosity and permeability due to leaching of calcium hydroxide and carbonation, and SLRA states they are not applicable. Since plant OpE has identified evidence of leaching of calcium hydroxide and carbonation in accessible areas. The component, material and environment for the increase in porosity and permeability due to leaching of calcium hydroxide and carbonation do exist in the inaccessible areas. Therefore, these AMR items shall be applicable, and Tables 1 and 2 line items shall also be included in the SLRA to manage the aging effects of increase in porosity and permeability due to leaching of calcium hydroxide and carbonation in the inaccessible areas.
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| SLRA Section 3.5.2.2.2.4 - Cracking Due to Stress Corrosion Cracking, and Loss of Material Due to Pitting and Crevice Corrosion-Structural
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| # SLRA Section SLRA Page Question / Issue 1 3.5.2.2.2.4 3-768 Item 052 - SLRA Table 3.5.2-1 shows that the stainless steel (SS) containment sump liner will be managed for loss of material and cracking due to exposure to standing water. What about SF gates, SF pit and the transfer canal liner? Are they exposed to standing water as well?
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| 2 3.5.2.2.2.4 3-770 Item 099 - states that the ASME Section XI, IWF program B2.1.31 will be used to manage the aging of stainless steel
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| SLRA Section 3.5.2.2.2.4 - Cracking Due to Stress Corrosion Cracking, and Loss of Material Due to Pitting and Crevice Corrosion-Structural
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| # SLRA Section SLRA Page Question / Issue components supports. Base on the program description in B2.1.31, it is not clear how the program was enhanced to include stainless steel components supports with the scope of the program.
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| The SLR-SRP recommends enhancing the selected AMP to properly manage this type of components.
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| SLRA Section 3.5.2.2.2.6 - Reduction of Strength and Mechanical Properties of Concrete Due to Irradiation
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| # SLRA Section SLRA Page Question / Issue 1 FE 3.5.2.2.2.6 3-771 The SPS sliding foot assemblies performances were assessed based on materials used. The SPS sliding feet were constructed in part from VASCOMAX steel and Lubrite. The VASCOMAX maraging alloy steel has yield stress in excess of 250 kilopounds per square inch (ksi).
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| The NAPS sliding feet according to FE 3.5.2.2.2.6 of SLRA are manufactured in part using AISI 4330 mod alloy steel. The AISI 4330 mod differs substantially from VASCOMAX both in chemical composition, strength, and durability (https://www.techsteel.net/alloy/steel/4330-mod). It is not clear whether the effects of aging due to radiation on AISI 4330 have been considered and whether stress corrosion cracking (SCC) is an issue that needs to be addressed during the subsequent period of extended operation.
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| 2 FE 3.5.2.2.2.6 B-87 The Appendix B OpE to SLRA AMP B2.1.12, Closed Treated Water Systems, folder in ePortal includes numerous condition reports (CRs) and work orders (WOs) on ongoing NAPS neutron shield tank (NST) leakage. It appears fluid level at NST Unit 2 at one time may have dropped to 13 percent. The staff requests a clarification which NSTs are/were leaking, where, by how much, and the duration of insufficient chromated water in NST(s), if any. The staff requests the applicant to mark up drawings showing areas of leakage in ePortal and further discuss NST leakage with staff so that the staff can evaluate the integrity and capacity of NAPS NSTs to maintain a level of chromated fluid adequate for managing loss of material in the tanks to the end of the subsequent period of extended operation.
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| 3 FE 3.5.2.2.2.6 B-90 The effects of aging (loss of material, corrosion) and internal integrity (cracking) of NST are managed with AMP B2.1.12, Closed Treated Water Systems. The SLRA AMP in its Operating Experience Summary states that [t]he Unit 1 and Unit 2 neutron shield tanks are monitored and trended in the Corrective Action Program every refueling outage for leakage. Although NAPS procedure CH-99.700, Closed Cooling Water Systems Chemistry Specification and Action Levels, and others (e.g., CH-99.701, Closed Cooling Water Systems Chemistry Strategic Plan) outline limits when
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| SLRA Section 3.5.2.2.2.6 - Reduction of Strength and Mechanical Properties of Concrete Due to Irradiation
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| # SLRA Section SLRA Page Question / Issue concentration of chemicals and diagnostic parameters NST are exceeded. The AMP B2.1.12 Appendix B Operating Experience Summary for Units 1 and 2 sampling indicates that these may not be adhered to.
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| Specifically, Unit 1 NST recorded chromates and conductivity over the last 8 years were quite high. Over the last 8 years, chromate concentrations averaged 5X the procedure limit and conductivity far exceeded the Electric Power Research Institute (EPRI) Closed Cooling Water Chemistry Guideline, Rev 2, dated 12/2013.
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| Since corrosion involves electrochemical reactions, an increase in the electrical conductivity of the NST electrolyte could be an indication of potential increased impurities in the electrolyte and steel corrosion rates.
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| Discuss acceptability of NST water chemistry and tracking parameters.
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| 4 FE 3.5.2.2.2.6 3-771 The SLRA states that [t]he configuration of the reactor vessel steel supports [] are similar between the North Anna Power Station (NAPS) and Surry Power Station (SPS) [] Thus, the analytical methods used to evaluate
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| [the] reactor vessel steel supports at SPS were used to evaluate the NAPS Concrete Biological Shield wall and reactor vessel steel supports for the subsequent period of extended operation. The staff evaluated the SPS reactor vessel (RV) steel support assembly based on the NUREG-1509 methodology and its implementation as noted in SPS SE. The staff notes that the applicant followed a different implementation of NUREG-1509 fracture toughness methodology. Since the two plants have similar RV steel support assemblies, discuss the driver to change the accepted SPS RV support evaluation. To what extent do materials, method of construction, and applied loads of NAPS and SPS NSTs differ?
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| 5 FE 3.5.2.2.2.6 Westinghouse LTR-REA-20-2 and LTR-REA-20-3 discuss a supplementary neutron shield. Although Westinghouse did not consider in its calculations the silicon based attenuating material, the LTRs reference UFSAR Section 12A.4, for its description/contribution.
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| The staff could not locate the said section in UFSAR Revision 55.03 included in the Non-Public SLRA.
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| Provide the missing Westinghouse referenced UFSAR sections for the staff to assess its need for added conservatisms in its evaluations.
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| 6 FE 3.5.2.2.2.6 3-777 The last paragraph on page 3-777 of the SLRA discusses the initial properties of the NST plates, namely the nil-ductility temperature values: -40°F at the inner shell of the NST and -20°F or better at other locations of the NST.
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| Pages 16 through 18 of ETE-SLR-2020-2204 discusses embrittlement of the NST plates.
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| The staff did not see a discussion of the initial properties and embrittlement of the weld and heat affected zones of
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| SLRA Section 3.5.2.2.2.6 - Reduction of Strength and Mechanical Properties of Concrete Due to Irradiation
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| # SLRA Section SLRA Page Question / Issue the NSTs. Provide this discussion. Note that per 4.3.4.1 of NUREG-1509, if the material toughness cannot be positively defined, fracture toughness should be based on KIR rather than KIC (having NDT data specific to the NST plates was the basis why KIC can be used for the NST plates). Note also that weld residual stress needs to be included in the applied loads for weld and heat affected zones.
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| 7 FE 3.5.2.2.2.6 3-779 Regarding Table 1 on page 3-779 of the SLRA:
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| (a) There is a minor typo on Table 1. Per page 18 of 24 of ETE-SLR-2020-2204, the critical stress for the Case 2 surface flaw shown in the table should be 30 ksi instead of 36 ksi.
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| (b) Clarify that the surface flaw analyzed in Table 1 is for a flaw that is quarter-thickness (1/4T) deep from the inside surface of the inner shell of the NST.
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| (c) Figures 1 through 4 of ETE-SLR-2020-2204 show plots of KIC vs stress. Confirm that the critical stress in Table 1 on page 3-779 of the SLRA came from these plots. Confirm the staffs understanding of how these KIC vs stress plots were determined: the applied K was set equal to KIC and the resulting stress from this applied K is the critical stress on the Stress axis in each of the plots.
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| 8 FE 3.5.2.2.2.6 3-778 to Pages 3-778 to 3-779 discuss Case 1 (use of 32 ksi yield 3-779 stress) and Case 2 (52 ksi yield stress). Page 21 of ETE-SLR-2020-2204 shows a table with Case 3 (42.9 ksi yield stress) and Case 4 (62.9 ksi yield stress). Cases 3 and 4 need to be added to the discussion in the SLRA.
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| 9 FE 3.5.2.2.2.6 3-780 Page 3-780 discusses ASME Section XI, Subsection IWF, which is the AMP for the RV sliding feet assemblies.
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| Section 3 of ETE-SLR-2020-2418 discusses inspections in 2011 (after the August 2011 earthquake) performed for the NAPS Units 1 and 2 RV sliding feet. CR448934 discusses the potential crack in the Unit 1 Loop B cold leg RV sliding foot brought up by NRC inspectors. Confirm that both the VT-1 and magnetic particle examination performed on the subject RV sliding foot showed no evidence of surface indications, and that no further fracture mechanics evaluation was performed on the potential crack. Were there any further examinations of any RV sliding foot after 2011?
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| SLRA Section 3.6.2.2.3 - Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections
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| # SLRA Section SLRA Page Question / Issue 1 A short section of transmission conductor on the 34 kV systems utilizes a conductor that is called Rope Lay. A
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| SLRA Section 3.6.2.2.3 - Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections
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| # SLRA Section SLRA Page Question / Issue vendor literature (Spec 80120) is provided in the portal for this component. The literature does not specify the material make up of Rope-Lay. SLRA section 3.6.2.2.3, as well as a drawing titled SBO Recovery Path Component Groups Aging Management Methods is also provided in the portal that mentions use of all aluminum conductor (AAC) transmission conductors only. Does the Rope-Lay consist of aluminum only?
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| 2 Drawing 1211034 Z.DGN, Operating One Line Diagram notes 41 and 42 mention aluminum conductor steel-reinforced cable (ACSR) transmission conductors. Are there any ACSR conductors used on the in-scope transmission conductors?
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| 3 SLRA Table 3.6.2 covers all items related to transmission conductors and switchyard bus connections. However, Item 3.6.1.004, Transmission conductors composed of aluminum; steel exposed to air-outdoor is not mentioned in Table 3.6.2. Please explain why Item 3.6.1.004 is excluded from SLRA Table 3.6.2 4 SLRA and some supporting documents mention that transmission connectors and switchyard bus connections were torqued during initial installation. There is no mention or evidence of use of Belleville washers or other mechanisms to resist loss of preload. How is loss of preload managed?
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| SLRA Section 4.1.1 - Identification of Time-Limited Aging Analyses (TLAA)
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| # SLRA Section SLRA Page Question / Issue 1 ETE-SLR-2020-2701 - TLAA Key Word Search - this was provided per NRCs request Can you walk me through the assessment that was done to identify TLAAs?
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| Was this ETE-SLR-2020-2701 the only assessment that was performed? This was basically only a key word search?
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| Was the engineering staff interviewed/approached?
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| 2 ETE-SLR-2020-2701 - page 30 of 315 FN -2003-052 - Safety Injection Accumulator and Charging Line Nozzle Environmental Fatigue - this was classified as NOT TLAA.
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| : 1. Can you discuss why this is NOT TLAA - this seems like it is about environmentally-assisted fatigue (a) Any other hits from this search that were NOT TLAA for the same reason - but would have expected it to be identified as a TLAA
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| SLRA Section 4.1.1 - Identification of Time-Limited Aging Analyses (TLAA)
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| # SLRA Section SLRA Page Question / Issue Without more context to this particular example -
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| I am curious if there were analyses that were identified as NOT TLAA when it should have been a TLAA.
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| 3 SLRA Section 4.7.5 Piping Subsurface Flaw Evaluations indicates that during the inservice inspections (ISIs) and evaluated in 1984 based on a fracture mechanics assessment in accordance with ASME Code, Section XI.
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| ASME Code, Section XI.
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| There werent any other flaws that were identified during ISIs since 1984?
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| o If there were - were these assessed via Appendix A/C flaw evaluations?
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| Are these also TLAAs for the SLRA - if not, why not?
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| o Trying to understand the rationale/logic that these Flaw Evaluations are TLAAs.
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| SLRA Section 4.2.2- Upper-Shelf Energy (USE) TLAA
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| # SLRA Section SLRA Page Question / Issue 1 4.2.2 4-27 to 4-30 Tables 4.2.2-1 and 4.2.2-2 cite PWROG-18005-NP (Note (a)), which in turn cites Dominion Calculation SM-1008 (Ref. 6 of Attachment 1 of PWROG-18005-NP). This SM-1008 is named as Dominion Calculation SM-1008, Revision 0, Addendum M in Ref. 6 of PWROG-18005-NP.
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| The document, CT-CALC-NFL-SM-1008, provided in the ePortal doesnt seem to be the same as SM-1008, Revision 0, Addendum M. Provide Dominion Calculation SM-1008, Revision 0, Addendum M in the ePortal.
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| 2 4.2.2 4-27 to 4-30 Note (e) in Tables 4.2.2-1 and 4.2.2-2 states data were taken in Dominion Calculation SM-1008. The staff could not find the values in SM-1008 (CT-CALC-NFL-SM-1008 in the ePortal). Help staff locate values referred to by Note (e), assuming the correct version of CT-CALC-NFL-SM-1008 is available in the ePortal (see #1 above).
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| 3 4.2.2 4-27 to 4-30 Tables 4.2.2-1 and 4.2.2-2 cite PWROG-18005-NP (Note (a)). Tables 9 and 10 of PWROG-18005-NP cite Dominion Calculation SM-1008 and WCAP-15112 Rev 2 (Refs. 6 and 5, respectively, of Attachment 1 of PWROG-18005-NP). The Upper to Intermediate Shell Circumferential Weld in Tables 4.2.2-1 and 4.2.2-2 of the SLRA appears to be termed Nozzle to Intermediate Shell Circular Weld in Dominion Calculation SM-1008 and WCAP-15112 Rev 2. Confirm that the terms in SM-1008 and WCAP-15112 Rev 2 are not nozzle-to-vessel welds, but do in fact refer to the same Upper to Shell Intermediate Shell Circumferential Weld referred to in Tables 4.2.2-1 and 4.2.2-2 of the SLRA.
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| 4 4.2.2 4-27 to 4-30 Tables 4.2.2-1 and 4.2.2-2 cite PWROG-18005-NP (Note (a)). Note (c) in Tables 9 and 10 of PWROG-18005-NP states that the Cu wt. % values were based on a ladle analysis. Are these ladle analyses documented? If so,
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| SLRA Section 4.2.2- Upper-Shelf Energy (USE) TLAA
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| # SLRA Section SLRA Page Question / Issue please provide documents in the ePortal. If not, explain how the reliability of the Cu wt. % values from the ladle analyses is ensured (i.e., how were the values quality-controlled and verified?).
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| 5 4.2.2 4-27 to 4-30 Tables 4.2.2-1 and 4.2.2-2 cite PWROG-18005-NP for initial USE values (Note (f)). Section 3.0 of Attachment 1 of PWROG-18005-NP (and repeated in the various sections in Attachments 2 and 3) states that USE is calculated based on an interpretation of ASTM E185-82 that is best explained by the most recent version of the ASTM E185 manual (2016 version). Confirm the staffs understanding: initial USE data were from already existing data (CMTRs or surveillance program) and USE was calculated from this data using ASTM E185-82, and referring to ASTM E185-16 merely to clarify the definition of USE in ASTM E185-82.
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| 6 4.2.2 4-27 to 4-28 Table 4.2.2-1 cites topical report PWROG-17090-NP-A for the initial USE of 56 foot-pound (ft-lb) for Inlet Nozzle Forging 11 (Note (c)). The NRC staffs Safety Evaluation (SE) in PWROG-17090-NP-A states that generic values in the topical report can be used only if no measured values of unirradiated USE Table 7 of Attachment 2 of PWROG-18005-NP shows CVN energy measured values for Inlet Nozzle Forging 11 of NAPS, Unit 1. Clarify that even though there are CVN energy measured values for Inlet Nozzle Forging 11 as shown in Table 7 of Attachment 2 of PWROG-18005-NP, USE cannot be defined based on those values because there is no %
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| shear data at the highest temperature shown, and that thus generic values from PWROG-17090-NP-A were used.
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| 7 4.2.2 4-29 to 4-30 Table 4.2.2-2 cites PWROG-18005-NP for the initial USE of Inlet Nozzle Forging 11 and Outlet Nozzle Forging 12 of NAPS, Unit 2. Table 6 of Attachment 1 of PWROG-18005-NP compares the original unirradiated (initial) USE with the updated unirradiated USE. The staff noted large increases in initial USE for the Inlet Nozzle Forging 11 (60 ft-lb to 75 ft-lb) and Outlet Nozzle Forging 12 (52 ft-lb to 60 ft-lb) of NAPS, Unit 2. All other changes in initial USE (shown in Tables 5 and 6 of Attachment 1 of PWROG-18005-NP) are either small increases, negative (meaning initial USE decreased), or have an explanation. The staff noted that the original initial USE values for the Inlet Nozzle Forging 11 and Outlet Nozzle Forging 12 of NAPS, Unit 2 came from the UFSAR and are therefore current licensing basis (CLB) values. Any explanation of why these CLB initial USE values are so different from those calculated from the CMTR data in Tables 7 and 8 of Attachment 3 of PWROG-18005-NP?
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| 8 4.2.2 4-31 to 4-36 This question is related to the use of Position 2.2 of RG 1.99, Rev. 2 regarding potential consideration of other plant data, such as data from the Master Integrated Reactor Vessel Surveillance Program (MIRVSP), for calculating decrease in USE. AMP B2.1.19 of the SLRA
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| SLRA Section 4.2.2- Upper-Shelf Energy (USE) TLAA
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| # SLRA Section SLRA Page Question / Issue states that Dominion is a member in the Reactor Vessel Working Group (RVWG) and participates in the MIRVSP even though it is not a requirement. Page 1-1 and Table 3-1 of BAW-2325, Rev. 1 (ADAMS Accession No. ML14162A108, responses to Generic Letter (GL) 92-
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| : 01) list plants in the MIRVSP, and NAPS Units 1 and 2 are not in this list. Can you confirm, then, that MIRVSP plant data has no relevance for NAPS Units 1 and 2 because NAPS Units 1 and 2 are not in the MIRVSP list of plants. (Note: Surry shared weld heats with MIRSVP plants.)
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| 9 4.2.2 4-31 to 4-33 Table 4.2.2-3 cites BAW-2356 for surveillance capsule data (Note (e)). Table 7-6 of BAW-2356 indicates the Weld Metal as Wire Heat 25541. Table 3-1 of BAW-2356 indicates that the weld metal contained in Capsule W has Weld Wire Heat 25531. Is 25541 a typographical error?
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| (Note that 25541 appears only twice in BAW-2356, in Table 7-3 and in Table 7-6, so it is likely that 25541 is a typo.)
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| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue 1 4.3.1 4-68 SLRA states The evaluation of fatigue is a TLAA for those major components and piping exposed to reactor coolant in the Reactor Vessel, RV Internals, and the Reactor Coolant System pressure boundary. In order to ensure the design cycles remain bounding in the Class 1 and component fatigue analyses, the Fatigue Monitoring program (B3.1) will track cycles for significant fatigue transients listed in Table 4.3.1-1 and ensure corrective action is taken prior to potentially exceeding fatigue design limits.
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| TLAA for Class 1, United States of America Standards 4.3.2.7 4-78 (USAS) (American National Standards Institute (ANSI))
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| B31.7 Piping is dispositioned in accordance with 10 CFR 54.21(c)(1)(i).
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| Why is the TLAA being dispositioned to (i) if SLRA is stating that Fatigue Monitoring Program is going to manage the number of cycles in fatigue analyses?
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| Shouldnt it be dispositioned in accordance with (iii)?
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| If the (i) disposition is applicable/appropriate - see questions related to cycle projections 2 4.3.1 4-68 SLRA states The evaluation of fatigue is a TLAA for those major components and piping exposed to reactor coolant in the Reactor Vessel, RV Internals, and the Reactor Coolant System pressure boundary. In order to ensure the design cycles remain bounding in the Class 1 component fatigue analyses, the Fatigue Monitoring program (B3.1) will track cycles for significant fatigue and transients listed in Table 4.3.1-1 and ensure corrective
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| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue action is taken prior to potentially exceeding fatigue design limits.
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| TLAA for reactor vessel internals is dispositioned in accordance with 10 CFR 54.21(c)(1)(i).
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| 4.3.5 4-102 Why is the TLAA being dispositioned to (i) if SLRA is stating that Fatigue Monitoring Program is going to manage number of cycles in fatigue analyses?
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| Shouldnt it be dispositioned in accordance with (iii)?
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| If the (i) disposition is applicable - see questions related to cycle projections 3 4.3.1 4-68 SLRA states The evaluation of fatigue is a TLAA for those major components and piping exposed to reactor coolant in the Reactor Vessel, RV Internals, and the Reactor Coolant System pressure boundary. In order to ensure the design cycles remain bounding in the Class 1 component fatigue analyses, the Fatigue Monitoring program (B3.1) will track cycles for significant fatigue and transients listed in Table 4.3.1-1 and ensure corrective action is taken prior to potentially exceeding fatigue design limits.
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| TLAA for high energy line break (HELB) is dispositioned in accordance with 10 CFR 54.21(c)(1)(i).
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| 4.3.6 4-103 Why is the TLAA being dispositioned to (i) if SLRA is stating that Fatigue Monitoring Program is going to manage number of cycles in fatigue analyses?
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| Shouldnt it be dispositioned in accordance with (iii)?
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| Also, the Fatigue Monitoring Program has an enhancement to the corrective actions program element related to HELB. Why is there an enhancement if the analyses are not being disposition in accordance with (iii) and with the Fatigue Monitoring Program to manage?
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| If the (i) disposition is applicable - see questions related to cycle projections 4 4.3.3 4-83 and 4-84 SLRA Section 4.4.3 states that Table 4.3.3-1 and Section 4.4.2 of WCAP-18503-P provide the basis for concluding that the number of cycles for each of these piping systems is projected to be less than 7,000.
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| Therefore, the USAS (ANSI) B31.1 allowable stress analyses remain valid for the subsequent period of extended operation.
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| Section 4.4.2 of WCAP-18503-P seems to focus only on the reactor coolant system (RCS) transients. CN-SDA-II-18-007 also did not seem to include this information.
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| Where did the information that supports SLRA Table 4.3.3-1 come from, specifically for those systems that do NOT reference SLRA Table 4.3.1-1 cycles (e.g.,
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| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue AAC, AB, AS, BD, CD, EG, HRS, HV, RH, SEC, and SS systems).
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| : 1. Where does the supporting information for the conservative basis for cycle projection come from for the systems in SLRA Table 4.3.3-1 that dont reference the RCS transients?
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| : 2. Discuss how these cycle projections were determined
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| - why are they appropriate/conservative to support (i).
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| : 3. Sampling system - discussion of what changed to go from 100 samples a cycle to only one sample per cycle - (i.e., procedural? System redesign? Seems to be a drastic change).
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| 5 4.3.1 4-68 and LRA CYCLE PROJECTION QUESTION Table 4.3.1-1 SLRA states the following A review of Fatigue Monitoring program (B3.1) data was performed to identify the number of cumulative cycles for each transient type that occurred at Units 1 and 2 up to November 8, 2017.
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| Baseline cycle counts were projected to an 80-year operating life based on the actual accumulation history over the last 10 years (November 8, 2007 -
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| November 8, 2017).
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| They do not represent a revision of the design basis.
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| These transient cycles and projections are shown in Table 4.3.1-1, 80-year Transient Cycle Projections.
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| Since most nuclear plants, including Units 1 and 2, have experienced a significant declining trend in accumulation of transients over time, transient projections based on recent OpE provide an appropriate basis for future projections.
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| Therefore, each monitored design transient was evaluated to determine if the recent 10-year trend had a consistent cycle accumulation rate. The 10-year rate cycle projection method was used to extrapolate the projected number of future occurrences beginning November 8, 2017 and ending at 80 years of plant operation. The end of the 80-year life is April 1, 2058 for Unit 1, and August 21, 2060 for Unit 2.
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| Questions:
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| : 1. Discussion as to why the projection method is conservative and supports (i).
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| o Was there any assessment/analysis of the projections to see if they were logical? Or was it just brute force/black box calculation (see CYCLE PROJECTION QUESTIONS)
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| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue
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| : 2. Based on CN-SDA-II-18-007 - there is more than one projection method - this information would be necessary to support the SLRA review and the safety evaluation report (SER) o The different projection methods are not discussed in SLRA - basis that these projections are conservative to support (i) are not discussed.
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| They are in a WCAP - but the information is not available for the staff to rely on it in the SE to support (i).
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| 6 4.3.1 NA CYCLE PROJECTION QUESTIONS SLRA states transient cycles and projections are shown in Table 4.3.1-1, 80-year Transient Cycle Projections.
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| Since most nuclear plants, including Units 1 and 2, have experienced a significant declining trend in accumulation of transients over time, transient projections based on recent OpE provide an appropriate basis for future projections. Therefore, each monitored design transient was evaluated to determine if the recent 10-year trend had a consistent cycle accumulation rate. The 10-year rate cycle projection method was used to extrapolate the projected number of future occurrences beginning November 8, 2017 and ending at 80 years of plant operation. The end of the 80-year life is April 1, 2058 for Unit 1, and August 21, 2060 for Unit 2.
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| In the review of just SLRA Table 4.3.1-1, some of the projections vs. current count do not appear reasonable/logical. The staff understands the length of remaining operating time is a factor (but there is only a two-year difference in operating time), - but without further explanation it is not clear. For example (did not identify ALL situations - just a sample):
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| o Accrued/Projection o Heatup -
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| 58/99 -Unit 1 55/113 -Unit 2 o Cooldown 57/98 - Unit 1 54/112 - Unit 2 o Reactor trip from full power 48/67 - Unit 1 49/90 - Unit 2 o Inadvertent auxiliary pressurizer spray transient 1/6 - Unit 1 0/2 - Unit 2 o I understand the two cycles were an assumption because zero cycles occurred in Unit 2. So if you had one cycle, it is expected that there would be three times more than if zero cycles occurred.
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| Same issue for some transients reported in CN-SDA-II-18-007
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| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue o Accrued/Projection o Charging Rate Increase by 50% & Charging Rate Decrease by 50%
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| 721/932 - unit 1 692/996 - unit 2 o Excess letdown from Crossover Leg 12/33 - unit 1 10/12 - unit 2 o Auxiliary Spray during RHR Operation 57/98 - unit 1 54/112 - unit 2 o Loss of Charging Pump 24/47 - unit 1 18/22 - unit 2 Further, some 80-year projection of transients identified in
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| - CN-SDA-II-18-007 are:
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| * Close the CLB limit.
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| o Charging Flow Shutoff and Return o Letdown Shutoff and Return o Regenerator Heat Exchanger Cooling Shutoff and Return
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| * Exceed the CLB limit o Loop drain o Loop fill
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| : 1. For the transients that have projections that exceed -
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| a (i) disposition doesnt seem appropriate because an assessment was performed of the fatigue analysis to determine that the projected cycles do not increase fatigue usage before the design limit of 1.0. The footnote in CN-SDA-II-18-007 for these transients seem to indicate some assessment was done to ensure the projected number of cycles is OK for 80 years of operation. This sounds like a (ii).
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| : 2. For the transients that have protection close to the CLB limit - a (i) disposition may not be the most appropriate, unless there is conservatism in the projection of cycles. Normally, there is margin in the projections and CLB limit - so there is confidence the analysis wont need to be revisited - but if the projections and CLB limit are close, there is no longer that margin.
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| 7 4.3 NA 2011 seismic event exceeded Design Basis Earthquake exceeded at certain frequencies.
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| : 1. Discussion of implications to fatigue analyses/TLAAs, if any.
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| : 2. Discussion of assessment to come to this determination.
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| START of Environmentally-Assisted Fatigue Questions
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| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue 8 4.3.4 Table 4.3.4-2 The supporting screening calc (SI calc 1701098.403) indicate that for some of the sentinel locations that fatigue monitoring is not required for component (vessel) locations, transient cycle monitoring is performed for all components (vessels).
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| SLRA Table 4.3.4-2 indicate that for some sentinel locations that under Fatigue Management Method column that None Required. Some of these locations have a footnote 14 - CUFen [environmentally-adjusted cumulative usage factor] less than unity. No fatigue management required per GALL-SLR. Transients for this location are monitored in the Fatigue Monitoring program. But some locations do not have this footnote -
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| (Section 3 - Charging (Normal and Alternate) and Section 2a - RHR (RHR plus High Head Injection Path).
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| : 1. The disposition for the Environmentally-Assisted Fatigue (EAF) TLAA is (iii) - so it is not clear if these sentinel locations in which a NONE REQUIRED for fatigue management method will be managed.
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| Discuss/clarify the discrepancy - and whether ALL sentinel locations will have some method of management under (iii).
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| : 2. If the disposition is (iii) for these NONE REQUIRED locations - but not being managed by a program -
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| we would like to understand the basis of how this is (iii)
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| : 3. If the disposition is NOT (iii) - would need a revision to the SLRA to clarify - and basis to support the new disposition.
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| 9 4.3.3 and 4.3.4 SLRA Table 4.3.3-1 indicates that the sampling for the RCS Hot Leg and RCS Cold Leg samples occurred at a rate of 100 samples/plant operating cycles pre-2015 and at a rate of one sample per plant operating cycles post-2015.
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| SLRA Section 4.3.4 states [c]onservative values are chosen for each of the environmental adjustment factor (Fen) input parameters: sulfur content, service temperature, strain rate, and dissolved oxygen (DO).
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| EPRI Technical Report TR3002000505, Pressurized Water Reactor Primary Water Chemistry Guidelines (Reference 4.8-41) is followed. Therefore, the Fen calculation considers a value of 0.005 ppm for the DO content when the system temperatures are elevated, which is the action level 1 value for pressurized water reactor (PWR) environmental conditions under normal operation. DO is sampled in the reactor coolant system five times per week and runs less than 0.005 ppm.
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| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue Are these two SLRA Sections referring to two different sampling points or sampling systems.
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| Please clarify?
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| There is a 2 year difference between the license expiration for Unit 1 and 2. (Unit 1 - 5742 cycles Unit 2 - 5261 cycles)
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| Why are there only 19 more remaining cycles for Unit 2 when considering there is only a delta of 2 years between license expiration - seems to be a lot of startup/shutdowns for a 2-year period.
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| Please clarify 10 4.3.3 SI Calc 1701098.403P R1 - There is a discussion of the rules to possibly reduce the number of sentinel locations.
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| Calc indicates that only Rule #5 was used (i.e.,
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| location with Uen * < 0.8) o Revised and used Uen * < 1.0 if sufficient difference between 80-year projected and analysis of record cycles.
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| o Can you provide a listing of the components per transient section where this modified Rule #5 was used?
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| o How many components were screened out because of the modified RULE #5 compared to the unmodified RULE #5.
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| o What is the comparison of the 80-year projected vs AOR - to determine that there is a sufficient difference 11 Page 9 of 1701098.403p R1 - indicates the two low alloy steel (LAS) 6260 locations are not retained as sentinel locations - Table 2 of calc and SLRA indicate that these locations are sentinel locations
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| : 1. Did I misunderstand the statement in the SI calc?
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| : 2. Are these locations sentinel locations or not?
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| 12 Walkthrough of the EAF screening Calc - Table 2 of 1701098.403p R1 Transient Section 1 Confirmation I understand the Calc/basis - 6 branch nozzle SI Cold Leg - bounds all the SS components because of thermal shocks seen by nozzle in comparison to other SS locations Transient Section 2 Confirmation I understand the Calc/basis - 12 branch nozzle accumulator cold leg - bounding SS location because it has highest UNREFINED Uen -
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| also experiences more significant thermal shocks
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| | |
| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue Need to understand the basis - why does the LAS RV outlet nozzles bound the other LAS components in this Transient Section.
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| o Additional discussion for supporting basis - did not see anything in the Calc o Especially consider CUFen for several locations are just under 1.0 and one location is over 1.0 o This question is tangentially related to the EPRI RULE #5 and modified RULE #5 for NAPS Transient Section 3 No questions Transient Section 4 No sentinel location selected because CUFen less than 1.0 o Accomplished by refined calcs What were these the result of? How were the calculations refined?
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| Are these new analyses of record for the CLB?
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| If yes, and cycle projections were used to reduce cumulative usage factor (CUF)- are these limits part of Fatigue Monitoring Program (FMP) o What is the difference between the Unit x Usage vs SLR Unit x Usage Transient Section 4 is a standalone listing of components to address EAF o A sentinel location was NOT selected because no CUFen was greater than 1.0 o However, the activity to demonstrate EAF is not an issue for Transient Section 4 was done by calculations - This appears to be a 10 CFR 54.21(c)(1)(ii) disposition.
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| o Please discuss thoughts.
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| Transient Section 5 SS components - no question LAS components o Calc indicates that location was removed because CUFen < 1.0 LAS components in Transient Section 5 do not appear to be included in BOUNDNESS Rule 1 or Boundness Rule 2 See questions in Transient Section 5 and 7 -
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| EAF was demonstrated to not be an issue for LAS components by calculation.
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| Fen = 37.460 for the PZR surge nozzle weld overlay -
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| this is much larger than I expected or have previously seen. Is there something unique?
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| Transient Section 4
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| SLRA Section 4.3 - Metal Fatigue
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| # SLRA Section SLRA Page Question / Issue Confirmation I understand the Calc/basis - PZR spray nozzle weld overlay - bounding SS location because it has highest CUFen LAS/carbon steel (CS) components o Understanding what happened for these components o See questions for Transient Section 5 and 7 nickel based alloy components o Understanding what happened for these components o See questions for Transient Section 5 and 7 o Why is the Fen = 128.1 - this is much larger than I expected or have previously seen. Something unique?
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| Transient Section 7 No sentinel location selected because CUFen less than 1.0 o Accomplished by refined calcs What were these the result of? How were the calculations refined?
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| Are these new analyses of record for the CLB?
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| If yes, and cycle projections were used to reduce CUF - are these limits part of FMP o What is the difference between the Unit x Usage vs SLR Unit x Usage Transient Section 7 is a standalone listing of components to address EAF o A sentinel location was NOT selected because no CUFen was greater than 1.0 o However, the activity to demonstrate EAF is not an issue for Transient Section 7 was done by calculations - This appears to be a 10 CFR 54.21(c)(1)(ii) disposition.
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| o Please discuss thoughts.
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| 13 SLRA Table 4.3.4 Section 2a (RHR) - 12 Branch nozzle Accumulator - indicates that NONE REQUIRED for FATIGUE MANAGEMENT METHOD SLRA Table 4.3.4-3 provides the ASME Code, Section XI, Appendix L Results for the 12" RCL Branch Accumulator Nozzle (Cold Leg) - RHR.
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| Page 9 of 1701098.403p R1 - indicates that a flaw tolerance evaluation was performed for this location
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| : 1. Can you discuss discrepancy? Is this location a sentinel location that is being managed by ASME ISI/Appendix L calcs/FMP because of the cycles?
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| 14 Page 7 of 1701098.403p R1 - discusses the exceptions to use of the Boundness RULES 1 and 2.
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| | |
| SLRA Section 4.3 - Metal Fatigue
| |
| # SLRA Section SLRA Page Question / Issue Provide a discussion of the use of Boundness RULE 1 and Boundness RULE 2.
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| Boundness RULE 1 - RRVCH j-groove weld (Transient Section 2) bounds pressurizer surge nozzle weld overlay (Transient Section 5) - I saw a brief discussion that the original CUF for the j-groove weld bounds the pressurize surge nozzle weld overlay.
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| I would have expected a more qualitative assessment why the one transient section bounds the other transient section when keeping these two components in mind o I saw the discussion about the as low as reasonably achievable (ALARA) concerns and the possibility of damaging cables Was there more of a technical basis or is mainly the ALARA concerns/damaging cables a concern o Seeking to understand the basis - if there is more of a technical basis - please provide the additional info regarding the supporting information to support this determination for these two locations o Boundness RULE 2 - SS pressurizer surge hot leg nozzle (Transient Section 5) bounds the nickel based alloy pressurizer sure nozzle weld overlay (Transient Section 5) - based on higher Uen and Fen values.
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| I would have expected a move qualitative assessment why the one material bounds another material in the same transient section o I saw the higher Uen and Fen statement - but expected more of a technical basis o Seeking to understand the basis - if there is more of a technical basis - please provide the additional info regarding the supporting information to support this determination for these two locations If I understand correctly - the pressurizer surge nozzle weld overlay is being bound by two locations -
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| j-groove and hot leg surge nozzle.
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| o Seeking to understand the technical basis for these conclusions.
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| SLRA Section 4.3.2.5 - Steam Generators (Including Unit 1 Inlet Nozzle Weld Overlays)
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| # SLRA Section SLRA Page Question / Issue 1 4.7 The design analyses in SI Report No. 1800069.403, Rev. 3, and SI Report No. 1800069.401, Rev. 3 indicate that the design life of some weld overlays is less than 80 years of plant operation. The SI reports also explain that the inspections specified in 10 CFR 50.55a(g)(6)(ii)(F),
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| ASME Code Case N-770-2 and subsequent versions of the Code Case are sufficient to confirm that the crack
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| | |
| SLRA Section 4.3.2.5 - Steam Generators (Including Unit 1 Inlet Nozzle Weld Overlays)
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| # SLRA Section SLRA Page Question / Issue growth and design life analysis is adequate and the structural integrity of the weld overlays is properly maintained. years of the plant operation. The SI reports also explain that the inspections specified in 10 CFR 50.55a(g)(6)(ii)(F), ASME Code Case N-770-2 and subsequent versions of the Code Case are sufficient to confirm that the crack growth and design life analysis is adequate and the structural integrity of the weld overlays is properly maintained.
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| In comparison, Dominion submitted the request for the weld overlay application submitted in 2011 (ADAMS Accession No. ML110900566). Attachment A, Section A1.4(c) of the request indicates that all the weld overlays should be inspected prior to the end of the weld overlay design life. The staff found a potential concern that the sampling-based inspections specified in ASME Code Case N-770 may omit these inspections.
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| Describe how the applicant will ensure that all the weld overlays are inspected prior to the end of the weld overlay design life.
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| 2 4.7 SI Report No. 1800069.403, Rev. 3 addresses the crack growth analysis for location 3 (stainless steel safe end location) near the Unit 1 steam generator (SG) inlet nozzle welds. Section 2.1.2 of the SI report indicates the location 3 away from the nozzle weld. This location has been evaluated in the crack growth and design life analysis.
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| Provide information to confirm that the examination volume for the weld overlays encompasses location 3 during the ISI.
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| 3 4.7 SI Report No. 1800069.401, Rev. 3 describes the crack growth analysis for locations 1 and 2 (weld and weld butter locations respectively) of the Unit 1 SG inlet nozzle welds. The report indicates that the crack growth rates of primary water stress corrosion cracking (PWSCC) in Alloy 82/182 are estimated in accordance with Materials Reliability Program (MRP)-420, which provides the updated crack growth rate equations from MRP-115 and MRP-55 (crack growth rates of Alloy 82/182 and 600 respectively).
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| : a. Discuss the technical basis of the PWSCC crack growth rate equations in MRP-420, which are the updates to MRP-115. In addition, clarify whether the crack growth estimates based on the MRP-420 equations for Alloy 82/182 dissimilar metal (DM) weld are conservative in comparison with the actual ISI results of the plant.
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| : b. Section 2.2.2 of the SI report also indicates the hydrogen concentration of the reactor coolant used in the crack growth analysis. Provide the basis of
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| | |
| SLRA Section 4.3.2.5 - Steam Generators (Including Unit 1 Inlet Nozzle Weld Overlays)
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| # SLRA Section SLRA Page Question / Issue selecting the hydrogen concentration value in the analysis.
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| 4 4.7 SI Report No. 1800069.401, Rev. 3 describes the crack growth analysis for locations 1 and 2 (weld and weld butter locations respectively). The SI report indicates that the PWSCC crack growth analysis for the weld overlay (Alloy 52M) uses a factor of improvement (FOI) described in MRP-386, which represents a reduction in the crack growth rate of Alloy 52/52M/152 compared to Alloy 82/182/132 (described in MRP-115).
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| The crack growth rate equations in [MRP-386] have not been generically approved. Therefore, the staff needs additional information regarding the crack growth analysis.
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| Clarify whether the crack growth estimates for the Alloy 52M weld overlay based on the FOI in MRP-386 are conservative in comparison with the ISI results of the plant.
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| SLRA Section 4.6 - Containment Liner Plate and Containment Penetrations Fatigue Analysis TLAA
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| # SLRA Section SLRA Page Question / Issue 1 Calculation Page 10 Calculation 11715-EA-14, Revision 0, Addendum 00D 11715-EA-14, states on page 10, for Condition 5: Temperature Revision 0, Difference, Dissimilar Material, that the condition does not Addendum 00D apply for containment liner and the cold penetrations evaluated for fatigue.
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| SLRA 3.5.2.2.1.5 and 4.6.1 3-758, 4-108 1. Clarify/confirm that the containment cold penetrations listed in SLRA Table 4.6.1-1 do not contain dissimilar material (e.g., DM welds).
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| 2 SLRA 3.5.2.2.1.5 Subject to the clarification in Item 1 above, Staff may use and 4.6.1 Attachment 04D Docketing Audit Information process to docket the following information for use in the SER [Staff will also consider if it is sufficient to make the observation in the audit report and use in SER]:
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| Based on the audit review of calculation 11715-EA-14, Reactor Containment Liner Analysis - Reactor Containment [Liner] and Cold Penetrations Fatigue Evaluation for 80-Year Plant Life, North Anna Unit 1 and Unit 2, Revision 0, Addendum 00D, the staff verified that each of the six conditions for fatigue waiver in the ASME Code, Section III, Paragraph N-415.1 were evaluated in the calculation and demonstrated to be satisfied for the NAPS Unit 1 and Unit 2 containment liner and containment cold penetrations due to stress fluctuations caused by pressure, temperature and design earthquake cycles for an 80-year plant operating term.
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| SLRA Section 4.7.1 - Fatigue Analysis of Cranes (crane cycle limits)
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| # SLRA Section SLRA Page Question / Issue 1 4.7.1 4-111 The SLRA states that the RHR pump monorails are not identified as TLAAs. The function of the monorails is to service/replace the RHR pumps. Stone & Webster J.O. 11715/12050, NAS-202 states that monorails were procured as CMAA-70, Class A compliant. SER to TER-C5506-372/373, Control of Heavy Loads VEPCO, NAPS U1 and U2 (NRC CONTRACT NO. NRC-03-81 130 to Franklin Research Center) lists the RHR monorails as NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, compliant. UFSAR 9.6.3 confirms that the RHR pump monorails are NUREG-0612 compliant. Guideline (7) to Section 5.1.1 of NUREG-0612 states that for overhead heavy systems for heavy loads the applicable design criteria satisfy ANSI B30.2-1976, "Overhead and Gantry Cranes and CMAA-70, "Specifications for Electric Overhead Travelling Cranes" or equivalent. The CMAA-70 provides fatigue design criteria and guidelines for lifting devices.
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| ePortal CA 14938.76-S-1, Revision 1, addresses monorail redesigns to clear SSCs. It states that U1 and U2 RHR monorails are designed to AWS D1.1-83, Structural Welding Code-Steel, AISC Manual of
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| | |
| SLRA Section 4.7.1 - Fatigue Analysis of Cranes (crane cycle limits)
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| # SLRA Section SLRA Page Question / Issue Structural Steel, and ANSI B30.11-1980. It also states that the plant will not be fully operating when these are to be used.
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| It is not clear whether the redesigned monorails remain NUREG-0612 compliant and therefore subject to CMAA-70 fatigue limitations.
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| 2 Procedure VPAP-0809, Revision 1 and Revision 10 list four U1 and U2 RHR pump monorails. ePortal Stone &
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| Webster J.O. 11715/12050, NAS-202 states that the monorails were procured as CMAA-70, Class A compliant. It is apparent from ePortal cellulations CA 14938.76-S-1, Revision 1 that the replaced RHR pump monorails were for Unit 1 and Unit 2. It is not clear however how many of the monorails were redesigned/replaced and whether those not redesigned/replaced remain as (originally intended)
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| NUREG-0612 compliant and therefore subject to CMAA-70 fatigue limitations.
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| 3 ePortal calculations CA 14938.76-S-1, Revision 1 indicate that the redesigned/replaced monorails in addition to standards discussed in question 2 are also designed for seismic loads. The anchor bolts (ABs) used in the design of monorails are 12 inches long Williams Rock Bolts and HILTI-KWIK ABs 9 inch long. VEPCO-NAPS Drawing 11715-FC-16BK, RHR Pump Monorail shows that 6 and 9 in long HILTI-KWIK ABs were used.
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| The drawing does not list/identify the Williams ABs.
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| Discuss whether the ABs used in redesigned/replaced monorails are adequate to sustain cyclic/lifts loads to the end of the subsequent period of extended operation.
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| 4 Table 4.7.1-2, Reactor Containment Polar Crane Operation, of the SLRA outlines the number of polar crane lifts over the plant life, currently projected to 80 years of operation. For each polar crane the estimated number of lifts are 32,182. In contrast Surry lifts were limited to less than 10 percent of those of NAPS. Given that the two plants are similar in construction, share maintenance procedures (for the most part), and had the same license renewal application for the subsequent period of extended operation, clarify the disparity in lift cycles between the two NPP sites.
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| SLRA Section 4.7.4 - Spent Fuel Pool Liner Fatigue Analysis TLAA
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| # SLRA Section SLRA Page Question / Issue 1 4.7.4 4-126, 4-127 No Questions but Staff plans to use Attachment 04D Docketing Audit Information process to docket the following information:
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| Based on the audit review of calculation, Calculation 11715-NMB-282-FC, Thermal Stress Analysis of Fuel Pool Liner - Fuel Pool Liner Fatigue Evaluation for 80 Years Plant Life, NAPS Units 1 & 2, Revision 0,
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| SLRA Section 4.7.4 - Spent Fuel Pool Liner Fatigue Analysis TLAA
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| # SLRA Section SLRA Page Question / Issue Addendum 00B, the staff noted that Dominion calculated the cumulative damage (or CUF) due to fatigue effects of thermal cyclic loadings for the controlling component (i.e.,
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| plate-stiffener weld) of the SFP liner from the three design conditions described in the SLRA to be 0.75. This is less than the acceptance criterion of 1.0.
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| SLRA 4.7.7 - Cracking Associated with Weld Deposited Cladding
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| # SLRA Section SLRA Page Question / Issue 1 4.7.7 4-134 The top of page 4-134 cites WCAP-18503-P*, which cites CN-SDA-II-18-007* Revision 1 (April 2020). The revision of CN-SDA-II-18-007 in the ePortal is Revision 0. Please put Revision 1 (April 2020) of CN-SDA-II-18-007 in the ePortal.
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| * Note: These documents are in the ePortal folders for TLAAs 4.3.1 and 4.3.2. The staff looked in these folders for transient information needed for the subject TLAA (SLRA Section 4.7.7).
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| 2 4.7.7 4-134 The top of page 4-134 cites WCAP-18503-P, which cites CN-SDA-II-18-007 Revision 1 (April 2020). CN-SDA-II 007 cites four other transients in the Schrader letter (ADAMS Accession No. ML19253B327)Feedwater Cycling and Boron Concentration Equalization, and two transients related to one RCS loop out of servicein WCAP-18503-P that were determined not to be applicable to NAPS, and therefore not in Table 4.3.1-1 of the SLRA. Section 4.3.3.1.5 of CN-SDA-II-18-007 (note that the staff looked at Revision 0 since that is the revision available in the ePortal; (Question 1 requests the latest revision) states that the NAPS UFSAR prohibits one loop out service. For the Feedwater Cycling and Boron Concentration Equalization transients, Sections 4.3.3.1.2 and 4.3.3.1.3 of CN-SDA-II-18-007 explains why these two transients are not likely to occur at NAPS. Has there been known cases when these two transients did occur? If these transients occurred, would operators know? Or is it simply that these two transients are not expected to occur because of the measures explained in Sections 4.3.3.1.2 and 4.3.3.1.3 of CN-SDA-II-18-007?
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| SLRA Section B2.1.1 - ASME Section XI ISI, Subsections IWB, IWC, and IWD
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| # SLRA Section SLRA Page Question / Issue 1 In February of 2018, an assessment of the Dominion Fleet ISI program was performed to determine compliance with American Society of Mechanical Engineers (ASME) Code, Section XI requirements, Dominion commitments, and industry risk-informed applications. There were eight recommendations that resulted from the assessment. Specifically, for NAPS, the staff noticed that a few items may still have not been fully addressed. Discuss corrective actions that were required and timetable for implementation.
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| | |
| SLRA Section B2.1.1 - ASME Section XI ISI, Subsections IWB, IWC, and IWD
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| # SLRA Section SLRA Page Question / Issue 2 In April 2019, an effectiveness review was performed for the ISI program, however there are no relevant details regarding this review on the portal. Provide information regarding areas that needed improvement as result of this review. If there are any items that have yet to be addressed, please explain.
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| 3 Provide information on the portal regarding the latest peer assessment (by industry peers such as the Nuclear Energy Institute (NEI), Institute of Nuclear Power Operations, etc.) performed on the ISI program. Discuss areas identified that needed improvement. Discuss corrective actions that were required and timetable for implementation.
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| 4 During the Spring 2012 outage, an ISI examination missed detectable flaws in a steam generator hot leg nozzle. Discuss 1) causal factors, 2) corrective actions taken, 3) any program deficiencies identified, and 4) bases that deficiencies, if any, have been corrected.
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| 5 During the Spring 2012 outage, an ASME Code B-N-1 examination was missed. Discuss 1) causal factors, 2) corrective actions taken, and 3) any additional ASME Code inspection items that were missed since 2012.
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| SLRA Section B2.1.2 - Water Chemistry
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.2 B-30 For the Water Chemistry AMP, OpE example #9 describes a January 2019 sodium excursion determined to have been caused by a leaking bearing cooling sample cooler. The description states that the cooler was isolated and will remain isolated pending system replacement via design change package.
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| : 1. Which unit was affected?
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| : 2. Was the system replacement performed?
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| : 3. Was this replacement determined to be the complete solution, or is there still a susceptibility such as another cooler of the same design?
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| : 4. If a susceptibility still exists, how is that being addressed?
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| SLRA Section B2.1.4 - Boric Acid Corrosion (AMP XI.M10/TRP 10)
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| # SLRA Section SLRA Page Question / Issue 1 GALL Boric Acid Corrosion: 5. Monitoring and Trending:
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| The program maintains a list of all active borated water leaks, excessive boric acid deposits, discoloration caused by corrosion, and affected targets susceptible to corrosion to track the condition of components in the vicinity of leaks and to identify locations with repeat leakage.
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| B2.1.11 OpE section discusses BACCP [boric acid corrosion control program] Monitor List for periodic inspections.
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| | |
| SLRA Section B2.1.4 - Boric Acid Corrosion (AMP XI.M10/TRP 10)
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| # SLRA Section SLRA Page Question / Issue PA 7503435 discusses the Active Leak list CR 1089316 discusses BACC Quarterly Monitoring List ETE-SLR-2020-2307, Section 3.5.2: Tracking of principle leak locations provides trending for the BAC program, and ER-AP-BAC-10 (2.4.7) states owner should trend all leakage events.
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| WCAP-15988-NP, 7.7 Documentation: A log or database of all borated water leak locations should be maintained for assessment, monitoring, and trending of the following conditions: a) wet (active leakage), b) excessive boric acid deposits, c) discoloration associated w/ rust or discoloration, d) targets affected that are susceptible to corrosion.
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| : 1. Provide current and previous versions of BAC active leakage list/database for each unit.
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| 2 B2.1.4, OpE B-40 OpE08-In Apr 2019 an effectiveness review was performed. The aging management activity was evaluated against the performance criteria identified in NEI 14-12. No gaps were identified.
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| PA 7503435 #3.AMA Effectiveness Review. Inspections are conducted at appropriate intervals such that degraded conditions were identified during the conduct of inspections and were not self-revealing in nature or led to a loss of function. During BACC walkdown inspections, ISI System Pressure testing or Plant Equipment Surv Test, NO conditions were self-revealing or led to a loss of function. Degraded conditions are identified during inspections and corrective actions are performed.
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| CR 1080698, Oct.-12,-2017 Boric Acid leak on 2-CH-TCV-2143.
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| CR 1089222, Feb. 2, 2018 Excessive Boric Acid leakage on 2-CH-TCV-2143 CR 1090645, Feb. 23, 2018 Leakage has returned on 2-CH-TCV-2143.
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| CR 1085633 Dec. 10, 2017 Inactive Boric Acid leak on 1-RP-ICV-3015 CR 1086967 Jan. 02, 2018 BACC leak has returned on1-RP-ICV-3015 CR 1088412 Jan. 22, 2018 Dried Boric Acid identified at packing area 1-RP-ICV-3015 CR 1088566 Jan. 24, 2018 Active Boric Acid Leak 1-RP-ICV-3015
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| : 1. Provide a discussion about apparent repeat leakage issues and how this reflects on AMP effectiveness.
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| SLRA Section B2.1.5 - Cracking of Nickel-Alloy Components
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| # SLRA Section SLRA Page Question / Issue 1 SLRA AMP SLRA AMP B2.1.5, Cracking of Nickel-Alloy Components B2.1.5 and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components From the review and search of the NAPS SLRA and ePortal, the staff did not find any documents indicating that Dominion has implemented the guidance in EPRI Report 3002017288, Materials Reliability Program:
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| Guideline for Nondestructive Examination of Reactor Vessel Upper Head Penetrations, Revision 1 (MRP-384),
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| as required under NEI 03-08 implementation criteria. In its search of NAPS ePortal, the staff identified CR1006123 EPRI Materials Reliability Program has issued Good Practice Requirements per NEI 03-08 (MRP-384).
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| However, the staffs review of CR1006123 did not find any relevancy to the contents of EPRI Report 3002017288.
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| Clarify whether and when the guidance in EPRI Report 3002017288 has been implemented at NAPS.
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| SLRA Section B2.1.6 - Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)
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| # SLRA Section SLRA Page Question / Issue 1 SLRA AMP Dominion Energy based the acceptability of thermal aging B2.1.6 embrittlement of CASS on its plant-specific evaluations as documented in the WCAP-18506, WCAP-15555, and PWROG-17033-P reports.
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| Provide the above reports in the ePortal.
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| SLRA Section B2.1.7 - PWR Reactor Vessel Internals
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| # SLRA Section SLRA Page Question / Issue 1 B2.7 Portal, AMP Is there any proprietary information in the following portal Evaluation Report documents: AMP Evaluation Report, CRs, CRs and Condition summaries, or CR listings located in the AMP Notebook Report (CR) XI.M16A.
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| Information, AMP Notebook Also please confirm that the NAPS units operate on 1.5 XI.M16A year fuel cycles.
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| 2 B2.7 Portal, AMP Please address whether NAPS ever submitted for NRC Evaluation review and approval an AMP inspection plan that Report, AMP addressed implementation of the original (2011)
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| Notebook MRP-227-A inspection and evaluation (I&E) guidelines for XI.M16A 60-year license term. Note that such a submittal would have included plant-specific responses to the eight action items in the NRC safety evaluation for the original MRP-227-A report.
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| 3 B2.7 Portal, AMP Please address whether 60-to-80 year changes to the Evaluation following time-dependent gap analysis inputs were Report, AMP considered on a plant-specific or a generic basis:
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| Notebook XI.M16A 1. Neutron Fluence
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| : 2. Fatigue CUF
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| SLRA Section B2.1.7 - PWR Reactor Vessel Internals
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| # SLRA Section SLRA Page Question / Issue 4 B2.7 Portal, AMP For SLR fatigue screening, Section 3 of the Enclosure to Evaluation MRP 2018-022 states: The threshold for fatigue required Report, AMP an update due to the combination of additional time to Notebook operate to 80 years (i.e., additional fatigue cycles) and XI.M16A recent developments in understanding the environmental effects on fatigue, which together resulted in a lower CUF for the fatigue threshold.
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| Please explain what actually changed for the NAPS 60-to-80-year gap analysis:
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| : 1. The CUF inputs for the reactor vessel internal (RVI) components
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| : 2. The CUF threshold (e.g., 0.1) considering EAF
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| : 3. Both the CUF inputs and CUF threshold.
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| 5 B2.7 Portal, AMP Page 2 of 17 of the gap analysis states that Clevis insert Evaluation bolts are listed as Expansion component in MRP-227, Report, AMP Rev. 1-A MRP-227, Rev. 1-A, Table 4-9 actually lists Notebook these as Existing Programs Components. Confirm that XI.M16A this is a typo.
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| 6 B2.7 Portal, AMP The plant-specific applicability requirements for MRP Evaluation 2018-022 (Section 2 of the MRP Enclosure) include Report, AMP confirmation that the RVI components fabricated from Notebook austenitic stainless steel which are not welds or bolting do XI.M16A not contain 20 percent or greater cold work. Please state whether the NAPS RVI components meet this criterion.
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| 7 B2.7 Portal, AMP Pages 3 and 4 of the gap analysis (portal) and the NAPS Evaluation OpE Detail Report (portal) address plant-specific Report; Portal, All degradation OpE for NAPS NAPS RVI Degradation Unit 1 and Unit 2 baffle-former bolting. However, the list Condition Report of nine plant-specific OpE issues in the portal AMP (CR) Info. Evaluation Report (Attachment 1) and in SLRA App. B address only the Unit 1 baffle-former bolt (BFB) degradation (OpE Item 3).
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| SLRA Appendix B Please state whether the CR information on the portal Pages B-53 to B- (CRs, CR summaries, CR listings, etc.) captures all of 56 NAPS plant-specific RVI component degradation issues encountered during the MRP-227 exams at the NAPS units, especially those that are not already documented in the list of nine plant-specific OpE issues in the SLRA.
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| 8 B2.7 Portal, AMP For NAPS, Unit 1 and Unit 2 BFB degradation, please Evaluation add portal information (e.g., full CRs and related Report, AMP evaluation documents) to address the following:
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| Notebook XI.M16A 1. Was the as-found degradation evaluated using acceptable bolting pattern analyses (ABPAs) based Portal, NAPS on NRC-approved methods (WCAP-15029-P-A or OpE Detail PWROG-18034-P-A.)?
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| Report, CR Nos. 2. Did the ABPAs support a 10-year reinspection CR 1048448 interval, based on structural margin alone? If not, (Unit 1 BFB) were BFB probabilistic predictive methods described in Revision 3 of WCAP-17096-NP, W-ID Item 6 (NRC
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| SLRA Section B2.1.7 - PWR Reactor Vessel Internals
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| # SLRA Section SLRA Page Question / Issue CR 1118597 review pending) used in determining the reinspection (Unit 2 BFB) interval?
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| : 3. Were any untestable bolts credited as functional structural members? If so, please provide justification for crediting the structural integrity of untestable bolts.
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| 9 B2.7 Portal, AMP NSAL-16-1, Revision 1 guidance for BFB bolting lists the Evaluation NAPS units as Tier 3, Converted Upflow Plants. Please Report, AMP state the calendar year(s) when the NAPS were Notebook converted from upflow to downflow.
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| XI.M16A 10 B2.7 Portal, NAPS CR1049685 addresses some evidence of control rod OpE Detail guide tube (CRGT) guide card wear found during Unit 1 Report, CR Nos. outage N1R25. Confirm that this wear is a separate CR1049685 relevant condition for Unit 1 CRGT guide cards compared CR1048581 to the oval shape of the tie-rod hole on Unit 1 CRGT J-7, Card 7, as addressed in CR1048581 and summarized in SLRA Appendix B SLRA App. B (OpE Item 4).
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| Pages B-53 to B-56 11 B2.7 Portal, CR 1093168 and SLRA Appendix B, OpE Item 7 discuss CR1093168 wear identified in March 2018 on the Unit 1 clevis insert mating surfaces and radial support keys. Please provide SLRA Appendix B on the portal photos of the wear indications, details on the Pages B-53 to B- exact location of the wear on the components surfaces, a 56 discussion of the root cause of the identified wear, and the engineering evaluation that accepted this condition as acceptable for continued service.
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| 12 B2.7 N/A Please confirm that the MURs below are the only power uprates that have been implemented at NAPS since issuance of the first renewed license in 2003.
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| NAPS U1 - 1.6% MUR, Approved Oct. 2009 NAPS U2 - 1.6% MUR, Approved Oct. 2009 13 B2.7 Portal, AMP SLRA Section 4.3.5 lists CUFs for the Lower Core Plate Evaluation (LCP) of 0.237 and Upper Core Plate (UCP) of 0.215 Report, AMP based on MUR structural evaluation and CLB design Notebook cycles. These CUFs are in excess of the 0.1 CUF XI.M16A threshold that is used in the 60-year MRP-191 fatigue screenings.
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| SLRA Section 4.3.5, Page 4- Are there any other plant-specific CUF values for NAPS 102, RV Internals RVI components other than those listed in SLRA Section Fatigue TLAA 4.3.5 for the LCP and UCP?
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| 14 B2.7 Portal, AMP Please address actions to implement NEI 03-08 needed Evaluation interim guidance for control rod drive mechanism (CRDM)
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| Report, AMP thermal sleeves in MRP 2018-027 based on NSAL-18-1.
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| Notebook XI.M16A 15 B2.7 Portal, AMP Please address whether or not any actions are needed Evaluation for the CRDM thermal sleeves based on NEI 03-08 Report, AMP Needed and Good Practice interim guidance in PWROG Letter OG-20-113 and NSAL-20-1.
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| SLRA Section B2.1.7 - PWR Reactor Vessel Internals
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| # SLRA Section SLRA Page Question / Issue Notebook XI.M16A 16 B2.7 SLRA Appendix B The SLRA App. B summary of gap analysis results Page B-51 includes CRDM thermal sleeve inspections based on SLR interim guidance in MRP 2018-022.
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| Please address whether this SLRA App. B item should be supplemented to include applicable NEI 03-08 Needed Interim Guidance in MRP 2018-027 based on NSAL-18-1.
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| 17 B2.7 SLRA Appendix B These SLRA App. B pages cite Revision 2 of Pages B-51 and WCAP-17451-P for I&E of the NAPS gap analysis B-53 expansion components, CRGT continuous Section C-tubes and sheaths. However, these sections do not Portal, AMP cite Revision 2 of WCAP-17451-P for I&E of the primary Evaluation component CRGT guide cards.
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| Report, AMP Notebook Please address whether these SLRA App. B pages XI.M16A should be supplemented to address the changes to I&E guidelines for CRGT guide cards in Revision 2 of WCAP-17451-P.
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| 18 B2.7 SLRA Appendix B The SLRA App. B list of AMP enhancements does not Pages B-52 and include the CRDM thermal sleeves, although this item is B-53 cited in the SLRA App. B gap analysis results on page B-51 and in several places in the portal AMP Evaluation Portal, AMP Report.
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| Evaluation Report, AMP Please address why SLRA App. B does not include an Notebook enhancement for inspections of CRDM thermal sleeves XI.M16A based on industry-published interim guidance for SLR in EPRI MRP 2018-022 (ADAMS Accession No. ML19081A061) and NEI 03-08 Needed Interim Guidance in MRP 2018-027 invoking NSAL-18-1.
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| 19 B2.7 SLRA Appendix B SLRA App. B includes AMP enhancements for the Pages B-52 and following components based on MRP-227, Rev. 1-A:
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| B-53 Eight out of nine Primary Components (missing the Portal, AMP internals hold down spring),
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| Evaluation Eleven out of eleven Expansion Components.
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| Report, AMP Notebook AMP enhancements for MRP-227, Rev. 1-A Existing XI.M16A Programs components address changes to inspection categories and inspection criteria based on industry-published interim guidance for SLR in EPRI MRP 2018-022 (ADAMS Accession No. ML19081A061)
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| Please address whether or not AMP procedures would need to be revised to address I&E of hold down springs and/or any of the MRP-227, Rev. 1-A existing programs components that are not elevated in MRP 2018-022.
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| SLRA Section B2.1.8 - Flow-Accelerated Corrosion
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| # SLRA Section SLRA Page Question / Issue 1 OpE associated with 2-BD-HCV-200B (SG low-capacity blowdown)
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| CR 117085 (Nov. 2008), Through-wall pinhole leak on downstream elbow of 2-BD-HCV-200B (B SG low-capacity blowdown hand control valve).
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| CR 1033983 (Apr. 2016) Steam Leak at 2-BD-HCV-200B Pin hole in elbow. Elbow is SS. Replaced elbow. No further info CR 1099475 (Jun-2018) 2-BD-HCV-200B Has Water Leakage Downstream of Valve. No info on aging effect.
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| SS Elbow replaced.
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| CR 117085 discusses leak on downstream elbow of 2-BD-HCV-200B, and OpE evaluation states the leak is not considered Flow-Accelerated Corrosion (FAC), but a water impingement issue. Notes that a new PM to replace this and similar components on a 6-year interval (N-PMTE-2007-0016). The subsequent CRs on this line (cited above) did not include the impingement discussion.
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| : 1. Provide explanation for not including CR 117085 in FAC OpE (It came out of M36 OpE). Address whether OpE keywords for M17 included impinge and implications if it did (how it was apparently missed) or if it didnt (are there additional CRs applicable to this AMP).
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| : 2. If replacement is every 6 years, (so it should have been replaced before 2014) then subsequent leak in 2016 and another leak in 2018 indicates 6-yr frequency is not sufficient. Provide information on i) how 6-year frequency was established, ii) what changed such that wall thinning is now apparently more severe than initially assumed, iii) whether more frequent periodic inspections are needed in lieu of periodic replacement.
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| ETE-CME-2019-0005, NA U2 2019 refueling outage (RFO) Results of FAC Program does not include any discussion about CR1099475 as part of the Operational review as required by Ref 12.4 [ER-AA-FAC-1003, FAC OpE Reviews]. Help me understand how the OpE reviews are performed as part of the FAC program and explain why this CR wouldnt be included as part of the operational review in accordance with ER-AA-FAC-1003.
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| 2 ETE-CME-2020-0005, Rev 1 ESE for U2.
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| : 1. (p47/200) says BD03, Low-Capacity Blowdown Subsystem, is not susceptible to erosion based on estimated usage <2% of operating time. Because OpE demonstrates that BD03 is susceptible to erosion (see question 1), provide information about
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| SLRA Section B2.1.8 - Flow-Accelerated Corrosion
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| # SLRA Section SLRA Page Question / Issue the cause of the erosion and address whether the programs <2% or <100 hrs exclusion criteria should be modified. [Note: EPRI 3002005530, Section 6.2.2 Exclusion of Systems from Evaluation, includes a caution that if service is especially severe, then the system should not be excluded based on operating time alone.]
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| : 2. Issue at Surry where OpE on a bearing cooling component was missed. (See Sep-03-2019 response to request for additional information (RAI)
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| B2.1.8-3a, Request 1 & 3). Is this a similar situation?
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| : 3. At Surry, exclusion criteria was changed to 100 hours per year (in accordance with EPRI TR-112657) unless the 2% time is justified. (See Sep-03-2019 response to RAI B2.1.8-3a, Request 2) Provide justification for the 2% exclusion being used at NAPS.
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| : 4. (p34/200) states Fire Protection system is excluded based on usage <2% time. How has periodic cycling of pressure maintenance pump 1-FP-P-6 been considered.
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| Based on the question, we are looking to add more notes to exclusion criteria.
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| Will there be additional notes added to the exclusion criteria?
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| 3 ETE-CME-2020-0013, Engineering Evaluation for North Anna Systems Excluded from Erosion Program Due to Low Operating Time, Rev 0. Methodology says Identified lines noted in the [ESE] as excluded from the erosion program due to fluid flow <2% of time. ESE (above) notes the BD03 and BD04 were excluded based on <2% usage. However, CME-2020-0013 does not discuss BD03 or BD04.
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| Explain why CME-2020-0013 does not address all systems that were excluded based on <2% usage (e.g.,
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| FP, BD-03, and BD-04).
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| 4 License Event Report LER 346/2015-002 (Jul-2015) and 286/2018-003 (Nov-2018) discuss modeling errors or mismodeling issues associated with the CHECWORKS.
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| [IN 2019-008 (Oct-2019) discussed these events.]
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| Provide documentation showing how these two OpE events were evaluated in the FAC program.
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| ETE-CME-2016-0002 (Unit 2 2016 RFO) & ETE-CME-2016-0007 (Unit 1 2016 RFO) Section 3. FAC Operational Experience Review does not include any discussion about the Davis-Besse LER or the associated PA. How does the OpE review in accordance with AA-FAC-1003 (FAC Op Ex Review) account for this?
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| (Similar to question being posed in #1).
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| SLRA Section B2.1.9 - Bolting Integrity
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| # SLRA Section SLRA Page Question / Issue 1 Basis Doc ETE- 3.2.2 Procedures (0-MCM-1006-01, Section 6.3.5 / 0-MCM-SLR-2020-2312 1006-02, Section 6.3.3 / etc.) note that fasteners should be lubricated with approved lubricant. How is it determined if lubricant is acceptable? Where is this guidance?
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| 2 Basic Doc ETE- 3.2.2 Section 3.2.2 states ASTM/ASME A/SA-193 Grade B7 SLR-2020-2312 bolts and ASTM-ASM A/SA-193 Grade 7 nuts may be used except when in contact with molybdenum disulfide lubricant or sealant. Is there guidance stating molybdenum disulfide lubricant is not acceptable?
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| 3 Basis Doc ETE- 3.3.2 & 3.2.2 Section 3.2.2 states that since the specified minimum SLR-2020-2312 values for yield strength are well below the threshold value of 150 ksi these bolts are not particularly susceptible to SCC.
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| Section 3.3.2 notes that pressure retaining bolting at NAPS is not high-strength and it references NAS-2094/NUS-2206, attachments 7.1 - 7.7. Several of these attachments have been marked-up to remove mechanical property requirements, including the minimum yield strength and associated notes. Are these redactions or actual edits to the document and if the documents have been edited how will it be ensured high-strength bolts are not used?
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| 4 Basis Doc ETE- 3.6.2 (pg. 43 of Basis document Section 3.6.2 (pg. 43 of 66) notes that SLR-2020-2312 66) plant-specific acceptance criteria will be identified in new and/or revised procedures for closure bolting where leakage is difficult to detect. Enhancement 3 also covers this topic.
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| Have the acceptance criteria been developed and if so what are the criteria?
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| 5 SLRA B2.1.9, Element 7 of the GALL Report AMP notes that additional Enhancement 3 inspections are completed within the interval (e.g.,
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| (pg. B-68) refueling outage, 10-yr inspection interval) in which the original inspection was conducted. Enhancement 3 states that additional inspections are completed within the 10-year inspection interval in which the original inspection was conducted. These statements do not appear to be consistent because the 10-year interval in the GALL AMP applies to sample-based inspections of submerged closure bolting and for air and gas systems; however, there are also other visible bolted joints for which inspection interval is every refueling outage.
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| Follow up Basis Doc ETE- 3.2.2 *follow up questions about the guidance in CY-AA-CTL-1/2 SLR-2020-2312 510, especially in regard to molybdenum disulfide.
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| Attachment 3 (pg. 52 of 70), Item 6 notes that lubricants do not require a CME if used as specified by the manufacturer or controlled in accordance with the station Lubrication Control Program. Is there another procedure or guidance document that
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| SLRA Section B2.1.9 - Bolting Integrity
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| # SLRA Section SLRA Page Question / Issue controls lubricants and if so does it have guidance about not using molybdenum disulfide?
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| Attachment 4 (pg. 53 of 70) provides a list of consumable materials that are restricted in use. It seems like molybdenum disulfide should be on this list is there a reason it is not captured here? There is a chance it is listed in this attachment Item 9 has been highlighted and due to the portal I am unable to read Item 9.
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| Follow up Basis Doc ETE- 3.6.2 (pg. 43 of Basis document Section 3.6.2 (pg. 43 of 66) notes that 4a SLR-2020-2312 66) plant-specific acceptance criteria will be identified in new and/or revised procedures for closure bolting where leakage is difficult to detect. Enhancement 3 also covers this topic.
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| Have the acceptance criteria been developed and if so what are the criteria?
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| SLRA Section B2.1.11 - Open-Cycle Cooling Water System
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.11 B-81 and OpE Summary B-82 The service water (SW) system spray array piping was replaced from 2005 - 2009, due to multiple leaks from 1998 - 2004.
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| Eight segments of SW piping were then replaced in 2015.
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| A review of test data from 2011 to 2020 did not identify any through wall leaks or spray nozzles that were not flowing.
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| A review of the CRs on the portal showed:
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| CR 1010918, September 2015 - Through-wall leak in 1B2 Spray Array Piping CR 1010927, September 2015 - TW leak in 2A2 Spray Array Piping CR 1076052, August 2017 - Nozzle clogged CR 1082583, October 2017 - 1 Nozzle and 9 drains inoperable CR 1088883, January 2018 - 1 nozzle and 8 drains clogged.
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| Q1. The five CRs listed to the left indicate through-wall leakage and clogged nozzles were identified between 2015 and 2018, which apparently contradicts the underlined statement at the left, taken from the SLRA.
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| 2 Op Exp Portion of Various CRs CR 332141, April 24, 2009 - All drains on Spray the portal Array 2B2 are blocked. Spray Array was just flushed on April 14, 2009.
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| CR 401729, November 2010 - All four 1-inch drains on 1A2 Spray Array are clogged CR 420511, April 2011 - 13 of the 32
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| SLRA Section B2.1.11 - Open-Cycle Cooling Water System
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| # SLRA Section SLRA Page Question / Issue 1-inch Spray Array drains are clogged. Arrays 2B1 &
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| 2B2 have all four of the 1-inch drains clogged.
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| CR 474014, May 2012 - All four drains on Spray Array 2A2 are clogged CR 474037, May 2012 - All four drains on Spray Array 2B2 were clogged CR 505905, February 2013 - 18 1-inch Spray Array drains clogged (partial & full)
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| CR 514781, May 2013 - 26 1-inch Spray Array drains clogged (partial & full)
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| CR 555377, August 2014 - Six 1-inch Spray Array drains not flowing CR 578708, May 2015 - 17 1-inch Spray Array drains clogged CR 1036291, May 2016 - 7 Spray Array drain lines plugged CR 1036294, May 2016 - 9 Spray Array drain lines plugged CR 1043682, August 1, 2016 - 6 Spray Array drains not draining CR 1043683, August 1, 2016 - Seven Spray Array drains not draining CR 1052429, October 31, 2016 - Five Spray Array drains clogged CR 1096093, April 2018 - 19 drains on eight Spray Arrays are clogged CR 1102474, July 2018 - 22 drains on seven Spray Arrays are clogged Q2. The Op. Exp. CR report on the portal indicates a long running problem with clogged drains in the Spray Array headers. Some examples are shown to the left.
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| Even after replacement of the Spray Array piping, all the drains on some headers were noted to be clogged (2009-2012), yet it isnt clear from these CRs whether this situation was documented as an operability issue or if it was an operability issue.
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| The amount of clogging appears to have decreased initially after the replacement of some 18-inch piping sections in 2015, but the trend in the number of clogged drains found in quarterly inspections appears to be increasing in 2018.
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| Q2a. Has the material clogging the drain valves been analyzed to determine if it is corrosion product from the pipe or some other form of sediment?
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| 3 VPAP-0811, Rev. Section 6.2.2b. Performance Testing states? that after 6 three tests, frequency should be changed based on test results to provide assurance that the equipment will
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| SLRA Section B2.1.11 - Open-Cycle Cooling Water System
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| # SLRA Section SLRA Page Question / Issue perform intended safety functions during intervals between tests.
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| Q3. With the extended Op Exp showing that drains are repeatedly clogging, should the requirement in 6.2.2b.
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| have driven some sort of performance testing change?
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| 4 CH-99.711, Rev. Section 6.2.1.3c states that current corrosion rates 0 appear to provide opportunities for improvements. The history of operational changes shown in CH-99.711 show that repeated changes to chemistry controls were made from 2008-2016, but no changes are noted since 2016.
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| Q4. Has the applicant concluded that the corrosion rate of the SW spray array piping has stabilized since 2016 and is now acceptable?
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| 5 0-PT-75.14A Attachment 1 shows some large bore piping only receives 180 degree ultrasonic testing (UT) inspections, while some receives 360 degree UT inspections.
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| Q5. Based on the OpE with the 18-inch piping, why is some 12-inch piping only receiving 180 degree UT inspections?
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| 6 Table 3.3.2-7 Spray nozzles in the SW system are noted to provide Service Water both a Pressure Boundary (PB) and Spray Pattern (SP) function. Similar nozzles in the Quench Spray (3.3.2-1),
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| Recirculation Spray (3.3.2-2), and Fire Protection (3.3.2-42) systems only provide an SP function.
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| Q6. What is the distinction in the SW system that makes these spray nozzles different?
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| 7 0-PT-75.11 Pages 9 & 11 Document notes in two places that spray array operability is not challenged unless ALL drains are clogged, and adequate freeze protection is provided with just one operating drain.
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| Q7a. Because of the range of pipe sizes in the spray array piping system (20-inch down to 6-inch), has it been verified that just one operating drain sufficiently drains all sections of array piping?
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| Q7b. What is the slope of the piping in the eight spray arrays and is the piping in each array configured in such a way that any one drain in an array can drain all the piping sections in the array?
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| 8 B2.1.11 LER 352/2019-001, Multiple Trains of RHRSW Inoperable for Greater than Time Allowed by [TS] Due to Pipe Corrosion, includes a discussion about a previously unseen corrosion mechanism in Limericks spray network distribution piping. According to the LER, the pipe degradation was due to flow-induced film removal accompanied by high humidity electromechanical atmospheric corrosion. It also states that it was not identified before the pipe became inoperable because
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| SLRA Section B2.1.11 - Open-Cycle Cooling Water System
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| # SLRA Section SLRA Page Question / Issue there was a lack of understanding of this potential failure mechanism.
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| Q8. Was this industry Op Exp evaluated as part of the SLRA reviews? (Did not see it referenced on the portal)
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| If not, explain how industry Op Exp was considered and provide an evaluation of the Op Exp.
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| 9 Op Exp Portion of CR 349095 This CR lists multiple CRs that document repeat non-the portal conformances in a review period as part of the execution of 0-PT-75.15 Generic Letter 89-13 Service Water System Testing Requirements Coordination. CR109340, dated 9/14/2008, describes a leak at a PVC flange in the Chemical Addition Building. While CR109340 indicates there is a PVC flange in the SW system, Section 3.3.2.1.7 and Table 3.3.2-07 of the SLRA do not indicate that PVC is a material in the SW system. Item 3.3.1-263 is an AMR item for polymer components; however, the discussion of ETE-SLR-2020-2314 (SW AMP Evaluation Report for OCCW) only includes flexible polymeric components, which doesnt appear to include rigid PVC components.
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| Q9. Please discuss where aging of PVC in the SW system is managed.
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| SLRA Section B2.1.12 - Closed Treated Water System
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.12 B-90 Op Exp section discusses the chromate concentration in the Neutron Shield Tanks, and how since 2010 the Unit 1 concentration has ranged between 2098 and 3142 ppm, while the Unit 2 concentration has ranged between 219 and 251 ppm. The normal operating range by procedure is between 150 and 500 ppm. It is stated that chromate levels >500 ppm can degrade carbon pump seals; however, since the neutron shield pumps do not have carbon seals and the system operates under natural circulation, the high concentration of chromate in the Unit 1 neutron shield tank is acceptable.
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| In September 2016, during a Unit 1 outage, the 1A neutron shield tank cooling water pump demonstrated seal leakage when the pump was placed in service to obtain a sample for chemical analysis.
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| Q1. A review of Drawing 11715 SLRM-079B Sheet 5 appears to indicate that the neutron shield tank cooling water pump listed above is the same as the neutron shield pump listed to the left. Please confirm or clarify, and if so, is there any possible causation between the pump leakage noted above and the chromate level in the Unit 1 tank?
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| SLRA Section B2.1.12 - Closed Treated Water System
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| # SLRA Section SLRA Page Question / Issue In September 2016, during a Unit 1 outage, the 1A neutron shield tank cooling water pump demonstrated seal leakage when the pump was placed in service to obtain a sample for chemical analysis.
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| SLRA Section B2.1.13 - Inspection of Overhead Heavy Load and Light Load (Related to Refueling)
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| Handling Systems
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| # SLRA Section SLRA Page Question / Issue 1 Basis Doc 3.1 Element 10 discusses initial license renewal one-time ETE-SLR-2020- inspections of uncoated interior of polar crane box 2316 girders. The one-time inspection provided assurance the uncoated carbon steel was not corroded why is a similar one-time inspection not necessary for SLR?
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| 2 Detailed CR CR 422309 Referenced CR identifies a crack in the I-beam rail. How Evaluation was this issue resolved?
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| SLRA Section B2.1.15 - Fire Protection
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| # SLRA Section SLRA Page Question / Issue 1 2.3.1.3, 3.0, 2-54, 3-93, 3-256, Section 5.5.1.3.12, Lube Oil Collection, of the UFSAR A1.15 of 3-288, A-11, states that an oil collection system is installed on the Unit Appendix A, B-102 1 and Unit 2 reactor coolant pumps (RCP) to reduce the B2.1.15 of chance of a fire due to lube oil leakage onto hot piping.
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| Appendix B Per Section 2.3.1.3, Reactor Coolant, of the subsequent license renewal application (SLRA) the RCP motor oil collection system is part of the reactor coolant system.
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| SLRA Section A1.15, Fire Protection, in Appendix A, UFSAR Supplement, and Section B2.1.15, Fire Protection, of Appendix B, Aging Management Programs, of the SLRA state that the Fire Protection Program manages loss of material for the RCP motor oil collection system.
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| The Discussion Column in Table 3.3.1, Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report, for Item Number 3.3.1-250 states that The RCP oil collection system is primarily composed of stainless steel components in an environment of waste water. Loss of material for these components is addressed in row 3.3.1-095. However, Item Number 3.3.1-095 does not refer to AMP XI.M26, Fire Protection. In addition, the RCP motor oil collection system components in Table 3.1.2-3, Reactor Vessel, Internals, and Reactor Coolant System
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| - Reactor Coolant - Aging Management Evaluation, does not reference AMP XI.M26.
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| Note: Section 3.3.2.1.42 does not include Lubricating Oil as an environment that fire protection system component types are exposed to.
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| The NRC staff is seeking clarification on why the AMP XI.M26 is not referenced in Tables 3.1.2-3 and 3.3.1
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| SLRA Section B2.1.15 - Fire Protection
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| # SLRA Section SLRA Page Question / Issue for the RCP motor oil collection system and why Section 3.3.2.1.42 does not include Lubricating Oil as an applicable environment that fire protection system component types are exposed to.
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| 2 2.3.3.42, 2.4.1.39, 2-149, 2-317, 3- Section 2.3.3.42, Fire Protection, of the SLRA states 3.0 295, 3-810, 3- structural fire barriers such as fire doors, fire-retardant 812, 3-868, 3- coatings, fire seals, and fire barrier penetration sleeves 880, 3-893 are evaluated as miscellaneous structural commodities.
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| However, Section 2.4.1.39, Miscellaneous Structural Commodities, of the SLRA states that Fire barrier walls, doors, floors, and ceilings are evaluated with the associated buildings and structures that are within the scope of subsequent license renewal.
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| Item Number 3.3.1-059 in Table 3.3.1 states that AMP XI.M26 manages loss of material due to wear for steel fire rated doors exposed to air.
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| Tables 3.5.2-2, 3.5.2-3, 3.5.2-29, and 3.5.2-34 for the Administrative, Auxiliary, Service, and Turbine Buildings, respectively, include AMP XI.M26 for managing loss of material for steel doors exposed to air. However, Table 3.5.2-39, Structures and Component Supports -
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| Miscellaneous Structural Commodities - Aging Management Evaluation, does not include fire doors and Note 1 does not include fire doors as a fire barrier component.
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| The NRC staff is seeking clarification on why Table 3.5.2-39 does not include managing loss of material by AMP XI.M26 for steel doors exposed to air.
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| 3 N/A N/A Based on NRC staff review of audit documents, the fireproofing and fire barrier materials in containment are stainless steel radiant energy shields for equipment and conduits, Marinite boards and Marinite splice boards for cable tray fire stops, silicon foam, Cerafiber damming material, and concrete elements.
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| Section 8.3.1.1.2.6, Criteria for Fire Stops and Seals, of the UFSAR states that Dow Corning Q3-6548 RTV Silicone Foam is used for fire stops and penetration seals.
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| The NRC staff seeks clarification on whether the materials listed above are all the fireproofing and fire barrier materials used in containment and clarification on whether Dow Corning Q3-6548 RTV Silicone Foam is used in containment.
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| 4 2.1.6.3, 3.0 2-37, 3-748, 3- Table 3.5.2-39 includes cracking and loss of material for 893 cementitious coatings, silicates, and subliming compounds used as fireproofing/fire barriers exposed to air. Note 2 to Table 3.5.2-39 that is associated with each of these materials states that Change in material properties is an aging effect not being managed.
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| SLRA Section B2.1.15 - Fire Protection
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| # SLRA Section SLRA Page Question / Issue Interim Staff Guidance SLR-ISG-Mechanical-2020-XX proposed to add AMR Items VII.G.A-805, VII.G.A-806, and VII.G.A-807 to Table VII.G in NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, and Table 3.3-1 in NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants.
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| The proposed aging effects for cementitious coatings, silicates, and subliming compounds used as fireproofing/fire barriers exposed to air were loss of material, change in material properties, cracking, delamination, and separation.
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| These aging effects are consistent with Section 6, Fire Barriers, of EPRI 3002013084, Long-Term Operations:
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| Subsequent License Renewal Aging Affects for Structures and Structural Components (Structural Tools),
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| November 2018.
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| Table 5-3, Structural Tools Comparison with GALL-SLR-Structural Concrete Members, in Section 5, Structural Concrete Members, of EPRI 3002013084 provides applicability criteria for aging effects/mechanisms for concrete structures and concrete components. Table 5-3 notes that change in material properties due to elevated temperature is applicable for concrete structures and concrete components when the general area temperature exceeds 150°F (65.6°C) or when the local area temperature exceeds 200°F (93.3°C). Therefore, applicants need to make a plant-specific determination of whether concrete structures and concrete components are exposed to temperatures exceeding these values.
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| This is consistent with FEs related to concrete exposed to elevated temperatures recommended in Chapter 3.5, Aging Management of Containments, Structures, and Component Supports, of NUREG-2192. Table 5-3 of EPRI 3002013084 also notes that temperatures exceeding these values potentially result in loss of material and cracking of concrete structures and concrete components.
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| Table 6-3, Structural Tools Comparison with GALL-SLR-Fire Barriers, in Section 6 of EPRI 3002013084 provides applicability criteria for aging effects/mechanisms for fire barrier materials. Table 6-3 notes that change in material properties due to gamma irradiation exposure is applicable for cementitious coatings, rigid fire boards (subliming compounds), and fibrous fire wraps (silicates) when exposures exceed 106 rads. A plant-specific determination would need to be made on whether cementitious coatings, subliming compounds, and silicates used as fireproofing/fire barriers would be exposed to greater than 106 rads.
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| SLRA Section B2.1.15 - Fire Protection
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| # SLRA Section SLRA Page Question / Issue Delamination and separation as applicable aging affects are discussed in Section 6 of EPRI 3002013084.
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| Note: Section 3.5.2.1.39 does not include change in material properties, delamination, and separation as aging effects associated with the miscellaneous structural commodities subcomponents.
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| The NRC staff is seeking clarification on why change in material properties, delamination, and separation were not identified as applicable aging effects for cementitious coatings, silicates, and subliming compounds used as fireproofing/fire barriers exposed to air.
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| 5 3.0, A1.15 of 3-893, A-11 Note 1 to Table 3.5.2-39 states that Fireproofing and fire Appendix A barriers include fire stops, fire wraps, fire barrier seals, coatings, and radiant energy shields. Table 3.5.2-39 notes that loss of material and cracking for stainless steel fireproofing and fire barriers exposed to air is managed by the Structures Monitoring Program (B2.1.15). However, SLRA Section A1.15 of Appendix A of the SLRA states that the Fire Protection Program manages loss of material and cracking for containment radiant energy shields.
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| The NRC staff is seeking clarification on the AMP that manages loss of material and cracking for stainless steel radiant energy shields.
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| 6 3.5.2.1.39 3-748 Section 3.5.2.1.39, Miscellaneous Structural Commodities, does not include concrete as an environment that miscellaneous structural commodities subcomponents are exposed to.
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| The NRC staff is seeking clarification on whether any miscellaneous fire protection and fire barrier commodities are exposed to concrete.
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| SLRA Section B2.1.16 - Fire Water System
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.16 of B-106 AMP XI.M27, Fire Water System, states that portions of Appendix B water-based fire protection system that are normally dry but periodically subject to flow and cannot be drained or allow water to collect are subject to augmented testing or inspections.
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| Section B2.1.16, Fire Water System, of Appendix B in the SLRA states that Portions of water-based fire protection system components that have been wetted, but are normally dry, such as dry-pipe or pre-action sprinkler system piping and valves, were designed and installed with a configuration and pitch to allow draining.
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| With the exception of two locations, Engineering walkdowns confirmed the as-built configuration that allows draining and does not allow water to collect.
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| SLRA Section B2.1.16 - Fire Water System
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| # SLRA Section SLRA Page Question / Issue Enhancement 5 to the Fire Water System in Section B2.1.16 states that The Unit 2 lube oil purification and hydrogen seal oil piping will have the piping pitch adjusted to improve drainage. A drain valve will be installed on the Unit 2 hydrogen seal oil fire protection piping to drain the line after system testing or initiation.
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| As part of the drainage reconfiguration, visual inspections and wall thickness measurements will be performed to identify unexpected degradation. Piping with unexpected degradation will be replaced.
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| There appears to be several Condition Reports (CRs) and Work Orders (WOs) on the portal related to this reconfiguration. The NRC staff is unclear of the current status.
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| The NRC staff is seeking clarification on whether WOs have been scheduled for the work on the Unit 2 lube oil purification and hydrogen seal oil piping and whether the WOs are available on the portal.
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| 2 N/A N/A The following WOs were related to the service water (SW) traveling screen degradation issue:
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| WO 102271193, WO 59102271194, WO 59102271195, and WO 59102271196.
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| The WOs refer to a word.doc on the SW traveling screen history. The NRC staff did not identify this document on the portal.
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| WO 102271193 noted a plan to replace all SW traveling screens over a 6-year period. Following replacement of one SW traveling screen in Unit 1, it was determined that the screen trays and screen chains only needed to be replaced for the remaining SW traveling screens. This would be done over a three-year period. The NRC staff is unclear of the status.
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| The NRC staff is seeking clarification on whether the word.doc referenced in the WOs related to the SW traveling screen degradation is available on the portal and what the status is of replacing the remaining SW traveling screen trays and chains. In addition, the staff is seeking clarification on whether there has been any degradation history with the circulating water traveling screens.
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| 3 2.4.1.18, 2.4.1.30, 2-288, 2-303, Section B2.1.16 includes an exception to Element 4, B2.1.16 of B-106 Detection of Aging Effects. Table XI.M27-1, Fire Water Appendix B System Inspection and Testing Recommendations, of NUREG-2191 recommends that the inspection and testing of fire pump suction screens follow NFPA 25 Section 8.3.3.7, Suction Screens. Section 8.3.3.7 of NFPA 25 requires the suction screens be inspected and cleared of any debris or obstructions following the
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| SLRA Section B2.1.16 - Fire Water System
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| # SLRA Section SLRA Page Question / Issue waterflow portions of the annual test or fire protection system activations. Note 10 to Table XI.M27-1 states that the testing and inspections can be conducted on a refueling outage interval if plant-specific OpE has shown no loss of intended function of the in-scope SSC due to aging effects being managed for the specific component (e.g., loss of material, flow blockage due to fouling).
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| As an alternative to inspecting the fire pump suction screens, Section B2.1.16 states that The circulating water and service water traveling screens will be monitored for a change in differential pressure since the water flow to the fire protection pumps travels through the respective circulating or service water traveling screens prior to the fire pump suction strainers. Section B2.1.16 goes on to state that Monitoring and trending of the circulating water and service water traveling screens dp
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| [differential pressure] will ensure clearing of any debris or obstructions from the fire protection suction is performed as a result of pump activations.
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| The discussion of the exception does not describe why the exception would be taken. In addition, the discussion does not address how this alternative would identify and manage degradation (loss of material) of the fire pump suction screen.
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| Sections 2.4.1.18 and 2.4.1.30, Service Water Pump House, of the SLRA state that The traveling screens are active components and do not require aging management. Its unclear to the NRC staff if the SW traveling screen degradation issue and the fact that the exception would rely on monitoring the traveling screens in place of inspecting the fire pump suction screens which are in-scope of SLR and subject to aging management were considered when making the determination that the traveling screens do not require aging management.
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| The staff is seeking clarification on the need for the exception to Element 4 and how the exception will identify and manage degradation of the fire pump suction screens. In addition, the staff seeks clarification on whether consideration of the SW traveling screen degradation issue and that the exception to Element 4 would rely on monitoring the traveling screens was considered as part of the determination of the traveling screens not being in-scope of license renewal and subject to aging management. Please discuss the justification for the overall determination.
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| 4 2.4.1.13, 3.0 2-282 Section 9.5.1.2.1, Fire Protection Water System, of the UFSAR states that the system pressure is maintained by a pressure maintenance system that consists of a jockey pump, a hydropneumatics tank with an air compressor, and related controls and accessories. Because the
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| SLRA Section B2.1.16 - Fire Water System
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| # SLRA Section SLRA Page Question / Issue hydropneumatics tank has an air compressor, depending on the design, there may be an air-water interface inside the tank where corrosion may occur. Section 2.4.1.13, Domestic Water Treatment, of the SLRA states that the hydropneumatics tank is evaluated with the fire protection system. However, Table 3.3.2-42, Auxiliary Systems, of the SLRA states that loss of material and flow blockage for steel tank (hydropneumatics) exposed to raw water (inside) is managed by AMP XI.M27. Air is not listed as an applicable environment.
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| The NRC staff is seeking clarification on whether there is an air-water interface inside the hydropneumatics tank. If there is an air-water interface, then the staff also seeks clarification on the applicable aging effects/mechanisms and the aging management activities that will be utilized.
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| 5 B2.1.16 of B-114 Section B2.1.16 states that Both the Unit 1 and Unit 2 Appendix B Turbine Building fire protection 10-inch and 12-inch deluge supply piping have been replaced or are scheduled to be replaced.
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| The NRC staff is seeking clarification on which deluge supply piping have been replaced and if the WOs for the remaining deluge supply piping have been scheduled and available on the portal.
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| 6 2.1.5.4 Feb-34 Section 3.1.2 of ETE-SLR-2020-2319, Revision 0, North Anna Subsequent License Renewal Project - Aging Management Program Evaluation Report - Fire Water System, states that aging of fire hoses is managed by the Fire Water System. However, Section 2.1.5.4, Consumables, of the SLRA includes fire hoses in Group (d) consumables and states that fire hoses are within the scope of subsequent license renewal but are not subject to aging management because they are replaced based on condition.
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| The NRC staff is seeking clarification on whether fire hoses are managed by the Fire Water System or replaced based on their condition or performance.
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| 7 B2.1.16 of A-61, B-111 Table A4.0-1 in Appendix A and Section B2.1.16 in Appendix B Appendix B of the SLRA includes the following commitment and enhancement, respectively: At each unit, a sample of 3 percent or a maximum of ten wet pipe sprinklers with no more than four sprinklers per structure shall be tested. Testing is based on a minimum time in service of fifty years and severity of operating conditions for each population. However, ETE-SLR-2020-2319 states that CM-AA-FPA-100 will be revised to include a one-time test of sprinklers that have been exposed to water. The above commitment and enhancement appear to be included as part of the one-time test.
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| SLRA Section B2.1.16 - Fire Water System
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| # SLRA Section SLRA Page Question / Issue Please note, neither Table A4.0-1 nor Section B2.1.16 discuss a one-time test of sprinklers that have been exposed to water.
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| The NRC staff is seeking clarification on whether the commitment and enhancement is a one-time test of sprinklers that have been exposed to water.
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| 8 N/A N/A Section 3.2.2 of ETE-SLR-2020-2319 discusses the requirement to plug the hydrant drain and pump out the water in the hydrant barrel if the hydrant barrel does not drain within 60 minutes. 0-MPM-0400-24, Revision 16, Frequent and Periodic Inspections and Lubrication of Hydrant Gate Valves & Post Indicator Valves, Mechanical Preventative Maintenance, North Anna Power Station, is listed as the reference for this information, however, the NRC staff did not identify it on the portal.
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| The NRC staff is seeking clarification on whether 0-MPM-0400-24, Revision 16, is available on the portal for review. The staff would like to review this document to verify the requirement to plug a hydrant drain and pump out the water in the hydrant barrel if the hydrant barrel has not drained within 60 minutes.
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| 9 N/A N/A Condition Report (CR) Numbers 320397, 439056, 439126, and 1062892 are related to leaking sprinkler heads or potentially leaking sprinkler heads. The NRC staff did not identify information related to follow-on inspections or maintenance related to these CRs on the portal. In addition, the staff did not identify information (basis for conclusion) regarding whether the leakage resulted in the inability of the sprinklers to meet their intended function.
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| The NRC staff is seeking clarification on the follow-on inspections or maintenance of the leaking sprinkler heads and whether the leakage resulted in the inability of the sprinklers to perform their intended function.
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| 10 N/A N/A CRs 1087239, 509752, 404465, and 1112931 are related to piping and drain blockage. The NRC staff did not identify information related to follow-on inspections or maintenance related to these CRs on the portal. In addition, the staff did not identify information (basis for conclusion) regarding whether the piping or drain blockage affected the ability of portions of the fire water system to perform their intended function.
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| The NRC staff is seeking clarification on the follow-on inspections or maintenance of the piping and drain blockage and whether the piping or drain blockage resulted in the inability of portions of the fire water system to perform its intended function.
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| 11 N/A N/A CRs 487704 and 1014771 are related to blockage in 01-FP-P-6 discharge piping and the piping from intake structure to the domestic water treatment building. It is
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| SLRA Section B2.1.16 - Fire Water System
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| # SLRA Section SLRA Page Question / Issue unclear whether the corrective actions are complete. In addition, the staff did not identify information (basis for conclusion) regarding whether the piping blockage affected the ability of portions of the fire water system to perform their intended function.
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| The NRC staff is seeking clarification on the status of the corrective actions for the blocked pipes and whether the piping blockage resulted in the inability of portions of the fire water system to perform its intended function.
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| SLRA Section B2.1.17 - Outdoor and Large Atmospheric Metallic Storage Tanks Program
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.17 Page B-121 CR 579764- OpE states Rain water leakage between the concrete missile shield and the outer surface of Unit 1 and Unit 2 Emergency condensate storage tanks (ECST) has been a chronic condition. It is not clear if the AMP has been enhanced to address this history of rain water leakage for both units.
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| CR 1042142- evidence of rain water intrusion between tank and missile shield.
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| It is not clear if the Gaskets/sealant/caulking will be inspected as these areas are not part of the interface tank and concrete interface caulking. Has the program been enhanced to inspect these areas that clearly shows there is a history of water intrusion?
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| SLRA Section B2.1.18 - Fuel Oil Chemistry
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.18 1724/1899 Description of the Fuel Oil chemistry listed the tanks in-scope for Fuel Oil Chemistry program. The description did not include the main Fuel Oil Storage Tank. No justification or exception were observed.
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| SLRA Section B2.1.19 Reactor Vessel Material Surveillance Program
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.19 B-135 SLRA states It is envisioned that one of the remaining untested standby capsules in each RV may also be tested for asset management considerations during the subsequent license renewal period. The remaining untested standby capsules in each RV are available to satisfy potential fluence monitoring requirements during the 20-year subsequent period of extended operation.
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| SLRA proceeds to discuss three potential capsules from each unit that would meet the 80-year projected fluence.
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| Is the applicant proposing to withdraw and test one of these capsules (Z, Y or T) from each unit during the SPEO in addition to Capsule X that is expected to be withdrawn (2025 for Unit1 and 2026 for Unit 2)?
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| SLRA Section B2.1.19 Reactor Vessel Material Surveillance Program
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| # SLRA Section SLRA Page Question / Issue 2 B2.1.19 Page 32 of 46 in Program Basis document states the PWROG did submit a topical report to the NRC for generic USE values for Rotterdam material (still awaiting NRC approval).
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| Which TR is it and What is the status? Is there any impact to this AMP? - Just wasnt clear since the TR seems to be associated with the SLRA Section 4.2?
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| Was it just discussed in the AMP for completeness and informational purposes?
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| SLRA Section B2.1.21 - Selective Leaching
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| # SLRA Section SLRA Page Question / Issue 1 Table 3.3.2 42 3-526 SLRA Table 3.3.2-42 includes buried ductile iron piping exposed to soil. In addition, as noted in TRP 014 issue No. 2, there may be buried gray cast iron piping exposed to soil in the fire protection system. Both materials are susceptible to selective leaching.
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| ETE-SLR-2020-2324, North Anna Subsequent License Renewal Project - Aging Management Program Evaluation Report - Selective Leaching, Revision 0, indicates that visual and mechanical inspection of selected components at both units will be performed for the following environments: CCCW-Chromate, CCCW-Glycol, treated water, raw water, and waste water. Soil is not listed as an environment within the scope of the program.
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| The staff seeks clarification if piping and piping components exposed to soil are being excluded from the scope of the program (and if they are, the technical basis for doing so).
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| 2 B2.1.21 B-150 SLRA AMP states the following: (a) the Selective Leaching program is a new condition monitoring program; and (b) a sample of 3 percent of the population or a maximum of ten components per population at each unit will be visually and mechanically (gray cast iron and ductile iron components) inspected.
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| NUREG-2222, Disposition of Public Comments on the Draft Subsequent License Renewal Guidance Documents NUREG-2191 and NUREG-2192, states the following regarding the staffs basis for reducing the extent of inspections for selective leaching in GALL SLR (i.e., 3 percent with a maximum of ten components) when compared to the extent of inspections for selective leaching in GALL Rev. 2 (i.e., 20 percent with a maximum of 25 components): the slow growing nature of selective leaching generally coupled with the inspections conducted prior to the initial period of extended operation provides insights into the extent of loss of material due to
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| SLRA Section B2.1.21 - Selective Leaching
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| # SLRA Section SLRA Page Question / Issue selective leaching that can be used in the subsequent period of extended operation.
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| The staff seeks clarification regarding why the reduced extent of inspections for selective leaching in GALL SLR are appropriate given that the Selective Leaching AMP is a new program (i.e., one-time inspections were not conducted prior to the initial period of extended operation).
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| 3 B2.1.21 B-150 SLRA AMP states the following: [f]or two-unit sites the periodic visual and mechanical inspections can be reduced from ten to eight because the operating conditions and history at each unit are sufficiently similar (e.g., flowrate, chemistry, temperature, excursions) such that aging effects are not occurring differently between the units. Past power up-rates were implemented for both units at approximately the same time. Historically, water chemistry conditions between the two units have been very similar. The raw water source for both units is Lake Anna.
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| As noted in TRP 033 issue No. 1, the scope of the program includes components exposed to a soil environment. The staff seeks clarification regarding if soil corrosivity testing has demonstrated that relevant parameters (e.g., soil resistivity, pH, moisture, redox potential, sulfides) are consistent across the site. The basis for the multi-unit reduction in the AMP only addresses aqueous environments (e.g., raw water).
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| SLRA Section B2.1.22 - ASME Code Class 1 Small-Bore Piping
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.22 B-156 SLRA Section B2.1.22 (page B-156) section related to RCP Seal Injection Thermal Barrier Socket welds states that: This injection pipe stub connects to the Thermal Barrier casing with a factory installed socket weld. There are also two capped pressure taps (no longer used) factory installed socket welds on each RCP. There are only nine of these ASME Code Class 1 socket welds per unit that constitute a unique subset within the small-bore socket weld population.
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| : 1. The Thermal Barrier socket weld population due to their unique design and operating history constitute a unique subset of socket welds at NAPS. This is based on original construction and operating history.
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| It appears that the NAPS, RCPs each have two capped pressure taps that are similar in design and fabrication to the three RCP seal injection piping-to-thermal barrier casing socket welds. It seems that the two capped pressure tap socket welds are not included in the total socket weld population of the Thermal Barrier socket welds for each unit. The weld
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| SLRA Section B2.1.22 - ASME Code Class 1 Small-Bore Piping
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| # SLRA Section SLRA Page Question / Issue population for each unit is listed as nine in the SLRA (page B-157). Discuss why the two capped pressure tap socket welds discussed in SLRA are not included in the same subset as the three socket welds for each of the RCPs.
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| : 2. As previously stated, it appears that each RCP for each unit has two capped pressure taps, which equates to six capped pressure tap welds for each Unit. In contrast, Dominion Energy document CM-AA-ETE-101, Attachment 2, North Anna Subsequent License Renewal Project - Aging Management Program Evaluation Report - ASME Code Class 1 Small-Bore Piping, Table 1-1 (page107) and Table 2-1 (pages 147 and 148) state that each NAPS unit has 12 RCP capped pressure tap socket welds.
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| Is the difference related to the cap to stub being a socket weld as well?
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| : 3. Discuss why the pressure taps to the RCP Thermal Barriers were capped, and when.
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| 2 B2.1.22 LRA Section B2.1.22 indicates that the six RCP internals are scheduled for replacement prior to the subsequent period of extended operation. Due to the noted cracking of the factory-designed Thermal Barrier socket welds, a modification to the original Thermal Barrier socket welds utilizing an improved weld design is currently being considered during the scheduled replacements for the RCP internals. The staff noted that during the most recent NAPS, Unit 2 refueling outage all of the Thermal Barrier socket welds for each RCP were examined using volumetric and liquid penetrant (LP) examinations and noted that similar examinations are scheduled for Unit 1.
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| : 1. a. Confirm that the results of the inspections for Unit 1 were acceptable and the procedure used provided adequate coverage to conclude that there are no service-induced cracking in the area of interest.
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| : 2. Explain how the results of these inspections for Units 1 and 2 will be used in deciding whether a modification to the original Thermal Barrier socket welds will be implemented.
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| : 3. If it is decided to have the original welds modified, when will these modifications be completed?
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| 3 B2.1.22 158-161 SLRA Section B2.1.22, subsection Operating Experience Summary (Pages 158-161) discusses OpE relevant to the NAPS, Small-Bore Piping AMP. Staff noted the SLRA discusses three reactor coolant system (RCS) leakage events, that are directly related to NAPS, ASME Code Class 1 Small-Bore Piping. These event were: 1) leakage identified in June 1994, for a socket weld on Unit 2 B RCP Thermal Barrier; 2) the leakage identified in December 2014, on the Unit 1 reactor coolant loop cold leg drain line; and 3) the leakage identified in April 2020, for a socket weld on Unit 2 A RCP Thermal Barrier.
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| SLRA Section B2.1.22 - ASME Code Class 1 Small-Bore Piping
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| # SLRA Section SLRA Page Question / Issue
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| : 1. The staffs review did not reveal any additional OpE of RCS leakage that can be attributed to NAPS, ASME Code Class 1, Small-Bore Piping. Please confirm that for NAPS there are no other RCS leakage events other than those cited above. If there are, please post them on the portal.
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| : 2. The staff noted that in 1994 the licensee identified the RCS leakage in Unit 2 when unidentified RCS leakage went from 0.2379 gallons per minute (gpm) to 0.9364 gpm. In December 2014, the licensee identified the RCS leakage in Unit 1 when unidentified RCS leakage increased to 0.053 gpm. In April 2020, the licensee identified the RCS leakage in Unit 2 when the unidentified leakage increased by approximately 0.08 gpm. When comparing the 1994 event to the 2014 and 2020 events, it appears that the licensee took action to identify the source of the unidentified leakage in response to significantly smaller changes in unidentified leakage. Please briefly discuss any changes in your procedures for managing unidentified leakage that resulted in the early detection and identification of the sources of RCS leakage in 2014 and 2020.
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| 4 B2.1.22 On June 11, 2007, the NRC issued Information Notice 2007-21 (IN 2007-21), Pipe Wear Due to Interaction of Flow-Induced Vibration and Reflective Metal Insulation.
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| With the issuance of IN 2007-21, the NRC alerted licensees of nuclear power plants of OpE related to significant wear marks on outside diameter of piping at a U.S. nuclear plant. The wear marks were caused by the interaction between the pipe and the reflective metal insulation on the pipe. The piping which was the subject of IN 2007-21 was ASME Code Class 2 piping. None of the wear marks were continuous or 360 degrees, with most being less than 180 degrees. There is now recent OpE (spring 2020) from US nuclear plants where additional instances of wear were identified in ASME Code Class 1 piping. The wear marks were deeper and extended nearly 360 degrees around the circumference of the piping.
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| : 1. Have you evaluated the NAPS ASME Class 1, Small-Bore piping AMP based on this new OpE?
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| : 2. If you have not evaluated the AMP based on the new OpE, when will this evaluation be performed?
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| SLRA Section B2.1.23 - External Surfaces Monitoring of Mechanical Component
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| # SLRA Section SLRA Page Question / Issue 1 Table 3.3.1 3-328 SLRA Table 3.3.1, Item 3.3.1-253. This item lists PVC piping exposed to raw water, raw water (potable), treated Item 253 water, and wastewater. However, there is only discussion of exposure to wastewater and there is no
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| SLRA Section B2.1.23 - External Surfaces Monitoring of Mechanical Component
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| # SLRA Section SLRA Page Question / Issue discussion about raw water, raw water (potable), or treated water.
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| Q1. In the discussion section of Table 3.3.1, it is not clear if the program is consistent with all NUREG-2191 listed components except for those items listed in the discussion section that claim use of a different AMP, or if some components and environments were not listed.
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| Please clarify.
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| 2 Table 3.3.1 3-314 SLRA Table 3.3.1, Item 3.3.1-172 for PVC piping states that the item is not applicable because NAPS has no in-Item 172 scope PVC piping exposed to air-outdoor.
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| The External Surfaces Op Exp folder on the portal contains CR1056102 dated December 17, 2016, which references PVC piping downstream of SW valve 2-SW-1122 that has been snapped in half.
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| Drawing 11715-SLRM-078A, Sheet 3 (area E-3) shows the piping leading to the Corrosion Monitoring Station downstream of 2-SW-1122, which is highlighted in orange and defined in the SLR Note 1 as performing a leakage or structural integrity function that corresponds to 10 CFR 54.4(a)(2).
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| Q2. Since the CR does not describe the failure mechanism for the PVC piping, staff cannot determine if being snapped in half is an aging mechanism requiring management per the GALL-SLR. It is also not clear from the drawing if this PVC piping is exposed to the sun.
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| Please confirm this piping is not exposed to outdoor air, discuss whether the failure mechanism was aging related, and whether Op Exp indicates that aging management activities will adequately manage the effects of aging for PVC piping covered by the External Surfaces Monitoring program.
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| SLRA Section B2.1.24 Flux Thimble Tube Inspection Program
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.24 B-170 through B- Program element - Detection of Aging Effects, 173 Monitoring and Trending, and Corrective Actions GALL-SLR (detection of aging effects) states Examination frequency is based upon actual plant-specific wear data and wear predictions that have been technically justified as providing conservative estimates of flux thimble tube wear. The interval between inspections is established such that no flux thimble tube is predicted to incur wear that exceeds the established acceptance criteria before the next inspection. The examination
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| SLRA Section B2.1.24 Flux Thimble Tube Inspection Program
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| # SLRA Section SLRA Page Question / Issue frequency may be adjusted based on plant-specific wear projections.
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| GALL-SLR (monitoring and trending) states Flux thimble tube wall thickness measurements are trended and wear rates are calculated based on plant-specific data using a methodology that includes sufficient conservatism to ensure that wall thickness acceptance criteria continue to be met during plant operation between scheduled inspections. Corrective actions are taken when trending results project that acceptance criteria would not be met prior to the next planned inspection or the end of the subsequent period of extended operation.
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| The program basis document (ETE-SLR-2020-2327, Attachment 1) does not seem to provide a discussion of how wear rates are projected, including the conservatism in the methodology. Discussion is provided that results are review/evaluated to ensure corrective actions are taken - but projection method is not discussed. It appears procedure 1/2-PT-210.4 references ET 0-04-0050, Incore Flux Thimble Eddy Current Test Frequency And Acceptance Criteria Evaluation -
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| uncertain if this procedure has the information Please provide a discussion about the projection/trending methodology to determine if the flux thimble tube will continue to meet the acceptance criterion by the next scheduled inspection Confirmation that the projections are based only on plant-specific results (i.e., not relying on results from other plants). If other data other than plant-specific data is used - discussion/basis on its use?
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| Please provide ET 0-04-0050 and brief discussion of it.
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| SLRA Section B2.1.27 - Buried and Underground Piping and Tanks
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| # SLRA Section SLRA Page Question / Issue 1 Table 3.3.2 42 N/A ETE-SLR-2020-2300, North Anna Subsequent License Renewal Project - Aging Management Program Evaluation Report - Buried and Underground Piping and Tanks, Revision 2, shows buried copper alloy fire protection piping within the scope of the program (page 20/101).
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| SLRA Table 3.3.2-42, Auxiliary Systems - Fire Protection - Aging Management Evaluation, does not include AMR line items for buried copper alloy piping.
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| The staff seeks clarification regarding if there is in-scope buried copper alloy piping at NAPS.
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| 2 B2.1.16 B-111 The application makes several references to buried gray B2.1.21 B-152 cast iron piping in the fire protection system (see bullets
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| SLRA Section B2.1.27 - Buried and Underground Piping and Tanks
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| # SLRA Section SLRA Page Question / Issue B2.1.27 B-190 below); however, there are no AMR items in SLRA Table 3.3.2.2.7 3-237 3.3.2-42 for this component, material, and environment combination. The application states that sections of buried gray cast iron piping were replaced with ductile iron in 2013, but there is no mention of a full-scale replacement. In addition, the bullets below describe failures due to cyclic fatigue (originating from pre-existing manufacturing flaws in the pipe). Cyclic fatigue is not an aging effect in GALL-SLR for this component, material, and environment combination (i.e., this would be a Generic Note H AMR item).
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| SLRA Section B2.1.16, Fire Water System, states
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| [i]n May 2013, sections of cementitious lined cast iron piping were replaced with a higher pressure rated cementitious lined ductile iron piping. Additional isolation valves were also installed to improve system sectional isolation capability. These modifications were implemented due to six fire protection pipe failures that occurred from 1984 to 2003 because of either manufacturing flaws or a flaw that was initiated during the installation process.
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| SLRA Section B2.1.21, Selective Leaching, states
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| [i]n October 2001 a rupture of fire protection main loop piping occurred. A metallurgical analysis determined that the failure most likely occurred as a result of a low cycle fatigue process that originated at a pre existing manufacturing flaw in the pipe. The ruptured piping was replaced.
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| SLRA Section B2.1.27, Buried and Underground Piping and Tanks, states [i]n May 2013, following replacement of cast iron with (and installation of new) ductile iron fire main piping, the scope of cast iron fire protection piping replacement with ductile iron was reduced to the portion identified as high priority due to the postulated pipe rupture in this area potentially challenging adjacent safety-related piping[t]he basis for scope reduction also included the good condition of existing fire piping found in at least five buried fire main locations.
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| 3.3.2.2.7, Loss of Material Due to Recurring Internal Corrosion, states [b]uried fire protection system piping is made of cast iron or ductile iron with a cementitious lining.
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| In May 2013, a design change was completed to replace sections of cementitious lined cast iron piping with a higher pressure rated cementitious lined ductile iron due to internal pipe failures that were attributed to preexisting conditions in the cast iron pipe and not due to the failure of the lining.
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| The staff seeks clarification regarding (a) if there is in-scope buried gray cast iron piping at NAPS; and (b) how
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| SLRA Section B2.1.27 - Buried and Underground Piping and Tanks
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| # SLRA Section SLRA Page Question / Issue cyclic fatigue will be managed during the SPEO (if there is in-scope buried gray cast iron piping).
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| 3 B2.1.27 B-187 GALL SLR Table XI.M41-1, Preventive Actions for Buried and Underground Piping and Tanks, recommends cathodic protection for buried steel piping and tanks.
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| SLRA AMP states the following:
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| The buried carbon steel piping of the service water system and the flood protection dike drain is protected by an active CP system.
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| The buried carbon steel piping of the fuel oil system for the emergency electrical power system will be refurbished and reconnected to the service water CP system described above.
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| The staff notes that in addition to carbon steel piping in the service water, flood protection dike, and emergency diesel generator systems; there is carbon steel piping exposed to soil in the security system and carbon steel tanks exposed to soil in the emergency diesel generator system.
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| The staff seeks clarification regarding why cathodic protection will not be provided for carbon steel piping in the security system and carbon steel tanks, consistent with GALL SLR Table XI.M41 1.
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| 4 B2.1.27 N/A External Coatings - Buried Steel and Stainless Steel Piping GALL SLR Table XI.M41-1 recommends external coatings for buried steel and stainless steel piping.
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| ETE-SLR-2020-2300 states the following: (a) buried stainless steel piping may be coated, wrapped, or tape-wrapped; (b) stainless steel piping is not required to be coated based on chloride index value of zero for each of the 24 soil sample locations throughout NAPS; (c) buried steel piping may be coated with coal tar epoxy, coal tar enamel, coal tar epoxy encased in concrete; or tape wrap.
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| The staff reviewed CR 1049897, Leak on SW line to U1 Aux[iliary] Feedwater, dated 10/06/2016 and noted the following: (a) the leak was caused by external corrosion; and (b) the investigation into the cause of corrosion identified that the [carbon steel] piping was not coated and wrapped in accordance with the installation specification.
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| SLRA AMP states the following in reference to Buried Piping and Valve Inspection Activities performed for initial license renewal: [t]he required inspections of in-scope stainless steel piping were conducted. In cases where stainless steel piping was found without coating or with
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| SLRA Section B2.1.27 - Buried and Underground Piping and Tanks
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| # SLRA Section SLRA Page Question / Issue significantly disbonded coating, no evidence of pitting or corrosion existed.
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| UFSAR Section 3.11.3, Corrosion Prevention for Underground Piping, states [t]he protective steps and measures taken are in accordance with National Association of Corrosion Engineers (NACE)
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| Recommended Practice RP-01-69. All underground steel pipelines and tanks are coated and wrapped in accordance with Section 5, Coatings, of the above standard. The standard does not address itself to stainless steel piping. Analysis indicates that no protective coating is required. However, to provide additional protection for the buried stainless steel Fuel Oil piping an approved coating will be applied.
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| External Coatings - Underground Steel and Copper Alloy Piping GALL SLR Table XI.M41-1 recommends external coatings for underground steel and copper alloy piping.
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| ETE-SLR-2020-2300 states that acceptable applied coatings for underground steel and copper alloy piping are coal tar enamel, coal tar epoxy, unidentified material, and none.
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| External Coatings - Buried Steel Tanks GALL SLR Table XI.M41-1 recommends external coatings for buried steel tanks.
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| External Coatings - Buried Fire Water System Piping GALL-SLR AMP XI.M41 states for fire mains installed in accordance with NFPA 24, "Standard for the Installation of Private Fire Service Mains and Their Appurtenances,"
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| preventive actions beyond those in NFPA 24 need not be provided if the system undergoes a periodic flow test in accordance with NFPA 25. The staff notes that NFPA 24 provides provisions for external coatings in Section 10.8.3.5, "Corrosion Resistance," and backfill quality in Section 10.9, "Backfilling."
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| NAS-74, Yard Water and Fire Protection Systems for North Anna Power Station, Revision 4, indicates that underground fire protection piping is cast iron with a cement mortar lining and bituminous coating.
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| Design Change No. 04-018, Underground Fire Protection Piping Replacement/ North Anna/ Units 1&2, dated 05/18/2006 indicates that buried ductile iron fire protection lines are coated with an asphaltic exterior coating.
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| SLRA Section B2.1.27 - Buried and Underground Piping and Tanks
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| # SLRA Section SLRA Page Question / Issue External Coatings - Buried Steel and Stainless Steel Piping The staff seek clarification regarding if buried steel and stainless steel piping is externally coated, consistent with GALL SLR Table XI.M41 1. ETE-SLR-2020-2300 states that buried piping may be coated, CR 1049897 discusses how buried steel piping was not coated in accordance with installation specifications, the SLRA describes buried stainless steel piping that was found without coating, and UFSAR Section 3.11.3 appears to indicate that only buried stainless steel fuel oil piping is externally coated.
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| External Coatings - Underground Steel and Copper Alloy Piping The staff seek clarification regarding if underground steel and copper alloy piping is externally coated, consistent with GALL SLR Table XI.M41 1.
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| External Coatings - Buried Steel Tanks The staff seek clarification regarding if buried steel tanks are externally coated, consistent with GALL SLR Table XI.M41 1.
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| For Surry, the staff reviewed a drawing and noted buried fuel oil storage tanks are coated externally with "poxitar or approved equal." Are there similar drawing(s) on the portal for NAPS that describe external coatings for these tanks?
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| External Coatings - Buried Fire Water System Piping It is the staffs understanding the buried fire water system piping is externally coated with a bituminous or asphaltic coating. The staff will consider a 4D to confirm.
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| 5 B2.1.27 N/A CR 498480, Unexpected backfill material found during buried pipe program inspection, dated 11/29/2012, notes the following: (a) unexpected backfill material was found against the surfaces of fire protection piping; (b) backfill material contains gravel above the size of Virginia Department of Transportation Grade B granular fill material specified for the fire protection replacement project (NAI-0034); (c) the original fire protection installation specification (NAS-0074) does not identify a maximum backfill material size; and (d) a formal Buried Pipe Program inspection was completed, and the external pipe coating was found not to be damaged.
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| The staff seeks clarification regarding how backfill quality for buried fire protection piping meets the intent of NFPA 24, Section 10.9.
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| SLRA Section B2.1.27 - Buried and Underground Piping and Tanks
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| # SLRA Section SLRA Page Question / Issue 6 B2.1.27 B-187 SLRA AMP states [t]he program includes an upper limit of -1,200 mV on cathodic protection pipe-to-soil potential measurements of coated pipes to preclude potential damage to coatings. This is consistent with GALL SLR Report AMP XI.M41 recommendations.
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| WO 59102888926, Vendor to ensure cathodic protection of the buried Service Water piping, notes that there was one section of subsystem B when the -1,200-volt value had been exceeded and hydrogen could be liberating.
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| 0-EPM-2303-01, Inspection of Service Water Cathodic Protection System, Revision 14, includes an upper bound of -1,500 mV (i.e., not -1,200 mV) for instant off potentials.
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| The staff seeks clarification regarding if the program includes a limiting critical potential of 1,200 mV to prevent damage to coatings or the base metal, consistent with GALL SLR Report AMP XI.M41 recommendations.
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| SLRA Section B2.1.28 - Internal Coatings / Lining
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| # SLRA Section SLRA Page Question / Issue 1 Table 3.3.2 19 3-399 SLRA Table 3.3.2 19, Auxiliary Systems - Chemical &
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| Volume Control - Aging Management Evaluation, includes internally coated flow elements exposed to treated borated water >60°C (>140°F).
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| GALL SLR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, states the scope of the program includes components exposed to closed cycle cooling water, raw water, treated water, treated borated water, waste water, fuel oil, and lubricating oil.
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| The scope of AMP XI.M42 does not include environments with elevated temperatures. The SLRA or UFSAR does not contain information regarding what the internal coatings are constructed of and the maximum temperature rating of the coatings.
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| 2 B2.1.28 B-200 SLRA AMP states [f]rom 2014 to 2019 recurring internal B-201 corrosion (RIC) due to loss of coating integrity has occurred in the coated service water (SW) system piping and component cooling heat exchanger channel head.
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| SLRA AMP states [p]lant operating experience has demonstrated that component cooling heat exchanger channel heads inspections performed on a three-year frequency which allows early detection of degradation of coatings and the underlying metal before there is a loss of intended function.
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| SLRA Section 3.3.2.2.7, Loss of Material Due to Recurring Internal Corrosion, does not discuss recurring
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| SLRA Section B2.1.28 - Internal Coatings / Lining
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| # SLRA Section SLRA Page Question / Issue internal corrosion of the component cooling heat exchanger channel heads.
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| GALL SLR Report Table XI.M42-1, Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers, recommends an inspection frequency of 4 to 12 years based on certain conditions.
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| The staff seeks clarification regarding why the inspection frequencies in GALL-SLR Report Table XI.M42-1 are appropriate for the component cooling heat exchanger channel heads in lieu of a three-year frequency.
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| 3 B2.1.28 B-195 SLRA AMP Exception No. 1 states [f]or each unit, existing piping inspections are performed on approximately 10 percent of the service water system (24 inch and 36 inch piping) internal coatings during each refueling cycle, thereby inspecting 100 percent of the service water system piping every 10 refueling cycles (15 years).
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| GALL SLR Report AMP XI.M42 states for two-unit sites where the piping sample size is not based on the percentage of the population (i.e., 50 percent), it is acceptable to reduce the total number of inspections at the site to 55 1-foot axial length sections of piping per unit.
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| The staff seeks clarification regarding how many linear feet of internally coated service water piping will be inspected every refueling cycle. This information could be used as part of a basis for the staff finding Exception No. 1 acceptable.
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| 4 Explain the basis and discuss citing no aging effects for PTFE (Teflon) coated components.
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| SLRA Section B2.1.29 - ASME Section XI, Subsection IWE
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| # SLRA Section SLRA Page Question / Issue 1 3.5.2.2.1.6 & 3-759, 3-804, Table 3.5.2-1 Containment Structure includes line item Table 3.5.2-1, A-21, B-205 with Note C associated with item 3.5.1-010 that credits Cracking of SS the App J and IWE AMP to manage cracking due to SCC Bolting; of stainless steel (SS) bolting.
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| B2.1.29; Section 3.5.2.2.1.6 states Visual examinations are A1.29 augmented with surface examinations to manage cracking due to SCC in the containment pressure-retaining portions of the fuel transfer tube (FTT), FTT enclosure, FTT blind flange, DM welds, and high temperature piping penetrations. . Enhancement 1 of B2.1.29 specifies surface examination for the above specific components.
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| SLRA Section B2.1.29 - ASME Section XI, Subsection IWE
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| # SLRA Section SLRA Page Question / Issue However, the NAPS AMP basis document, CISI Basis and Plan documents, nor any of the implementing procedures on the ePortal for the IWE AMP (XI.S01) do not specify surface examination for containment stainless steel bolting. Nevertheless, SLRA Section A1.29 states This program also includes surface examination for the detection of cracking of structural bolting.
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| : 1. State if the program Enhancement 1 for surface examination for specific components in the SLRA B2.1.29 IWE AMP include SS bolting component. If so, why is it not explicitly called out?
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| : 2. How is surface examination of SS bolting incorporated in the B2.1.29 IWE Program?
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| 2 B2.1.29 B-205 Enhancement 1 states Procedures will be revised to augment visual examinations with surface examinations (or other applicable technique) to manage cracking in Surface examinations will be performed once during each 10-year period.
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| : 1. For the option or other applicable technique to be included in the enhancement, describe and justify the adequacy of the other applicable technique that will specifically be used to detect cracking due to cyclic loading with inspection interval, or alternatively remove the phrase (other applicable technique) in the enhancement.
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| 3 A1.29, Table A-21, A-80, B-205 UFSAR Supplement Section A1.29 (and B2.1.29), with A4.0-1 (Item 29), regard to the one-time volumetric examination of liner (if B2.1.29 triggered by OpE) states, Sampling locations will be those susceptible to loss of thickness due to corrosion of the containment liner that is inaccessible from one side.
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| The corresponding language in Enhancement 2 of B2.1.29 (LR Commitment 29(2) in Table A4.0-1) which states, .The supplemental volumetric examination consists of a sample of .locations that include both randomly-selected and focused areas most likely to experience degradation based on operating experience and.
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| These statements in the UFSAR supplement description and the LR Commitment appear inconsistent in that the UFSAR description does not include randomly-selected areas.
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| : 1. Clarify the above inconsistency in description regarding sampling locations.
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| 4 Table A4.0-1 A-80, OpE #1 for B2.1.29 AMP indicates NAPS Unit 2 had a (item 29), B2.1.29 B-206, 3-754 plant-specific OpE of through-wall liner corrosion that and 3.5.2.2.1.3.1 initiated on the inaccessible (concrete) side in Sept. 1999 (before first renewed license issuance) and attributed to embedded foreign material in the containment concrete.
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| SLRA Section B2.1.29 - ASME Section XI, Subsection IWE
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| # SLRA Section SLRA Page Question / Issue SLRA Section 3.5.2.2.1.3.1 states there have been other documented instances of foreign material embedded in the containment concrete.
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| The implementation schedule indicated for the related LR Commitment (29)(2) in Table A4.0-1 (for one-time volumetric examination of liner) is associated with prior to entering the SPEO (which may or may not be the only possible case), rather than the identification of the OpE. It does not cover the case where the triggering OpE occurs during the SPEO.
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| : 1. Confirm whether or not a plant-specific OpE of through-wall containment liner corrosion has occurred at NAPS Units 1 or 2 since the issuance of the first renewed license.
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| : 2. Also, provide an implementation schedule (relative to the date of occurrence of the triggering OpE) for implementation of the one-time supplemental volumetric examination that covers the case where the triggering OpE occurs during the SPEO.
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| : 3. Further, describe the treatment of the two NAPS Units when the triggering OpE occurs in one with regard to sampling locations considerations for the conduct of the one-time OpE-triggered volumetric examination of the containment liner.
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| 5 NAPS 3rd CISI 20 of 27 CISI Basis Section 5.4, Augmented Examinations - IWE, Interval Basis states The containment inspection history, plant history Document - and design were reviewed to determine augmented Section 5.4; inspection requirements. The program and the plan document the area requiring examination.
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| IWE-1242 requires that Surface areas requiring augmented examination shall be determined in accordance with IWE-1241 and shall be identified in the Owners Inspection Program.
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| ER-AA-CII-102; 3 of 10 Per Section 3.1.1 of ADM Procedure ER-AA-CII-102, the CISI-IWE Plan shall as a minimum, among others, contain the classification and identification of components subject to examination and test.
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| NAPS CONT IWE However, the NAPS Third 10-Year CISI Plan does not PLAN appear to identify any specific surface areas requiring augmented examination as required by IWE-1242 or IWE-2420(b).
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| : 1. Clarify if there are areas/surfaces identified for NAPS 1 and 2 containment liner that are subject to augmented examination required by IWE-1242 or IWE-2420(b)? Where is that determination documented?
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| SLRA Section B2.1.29 - ASME Section XI, Subsection IWE
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| # SLRA Section SLRA Page Question / Issue
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| : 2. Discuss the conditions and areas requiring augmented examination in the NAPS IWE program for the current inspection interval.
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| : 3. How does the IWE Program Plan identify and document areas/surfaces subject to augmented examinations?
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| 6 ePortal:XI.S01 The OpE of containment liner corrosion degradation OpE Background/ identified in 3/2019 in CR 1117899 that apply to Unit 2 Unit 2 IWE Moisture Barriers (Summary No. N2.E1.30.001) and Inspection Data Containment Liner in Keyway/Incore Instrumentation Area (Summary No. N2.E1.11.286) appear to be the most WO59203136641, significant recent OpE of the containment liner and is not Unit 2 captured in the SLRA B2.1.29 OpE descriptions. This ISI(N2R26_2019) OpE appears to have been accepted by engineering IWE pages 785- evaluation and identified to require re-examination (or 837.pdf augmented examination) in accordance with IWE Examination Category E-C Item E4.11.
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| : 1. Discuss details of the above stated OpE and explain its significance on containment liner function, how it has been or proposed to be resolved to closure within the IWE Program.
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| 7 B2.1.29 B-203 & B-207 Second paragraph of Program Description states Plant OpE has not identified any discernible bulges requiring further examination. However, OpE Summary Item 6 indicates OpE of bulge that required evaluation.
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| : 1. Clarify if there are any other instances of discernible bulges identified for NAPS 1 and 2 containment liner that required evaluation.
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| : 2. Provide on ePortal the engineering evaluation of the bulge identified in SLRA OpE #6.
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| 8 B2.1.29 B-203 SLRA states that There are no ASTM A325 and/or ASTM A490 bolts (including respective equivalent twist-off type ASTM F1852 and/or ASTM F2280 bolts) within the scope of ASME SC XI, Subsection IWE program.
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| : 1. How is it ensured that components in the IWE program will continue to not use the above specified bolts during the subsequent period of extended operation?
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| 9 General Request the following documents to be provided on the document request ePortal for the B2.1.29 (XI.S01):
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| : 1. In CR 1029653 regarding OpE #6, provide the stated engineering evaluation performed for bulge.
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| : 2. Provide CR 1094362 and CR 1094363.
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| : 3. Provide CR 373299 and design change package (DCP) NA-09-00133 with pictures of degraded test channel connection plugs
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| : 4. Provide drawings of containment floor leak chase channels and test connections (e.g. Drawing 11715/12050-IWE-M001/M002/M003)
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| SLRA Section B2.1.29 - ASME Section XI, Subsection IWE
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| # SLRA Section SLRA Page Question / Issue
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| : 5. Provide CR 1095927 and WO 59102859373 to closure associated with containment liner degradation in Key Way below Incore Instrumentation Area. Also, provide related CR 1119578 and WO 59203286867.
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| : 6. With reference to PIR1112472 (OpE #11), provide results of effectiveness review performed with regard ISI and augmented examinations specifically related to ASME Section XI, Subsection IWE AMP.
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| SLRA Section B2.1.30 - ASME Section XI, Subsection IWL
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| # SLRA Section SLRA Page Question / Issue 1 Detailed CR CR 472650 Referenced CR discusses a crack in containment and Evaluation limitations on loads on the containment due to the crack.
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| Closure discusses engineering assignments CA 233394 and CA 233395 for the long-term repairs. Provide more information about this crack and how the issue was ultimately addressed.
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| 2 ETE-NA-2016- Discussion The summary reports for the 2016 IWL inspections for 0072 in Attachment 2 both units identify multiple instances of embedded foreign (pg. 3 of 6) material in the concrete (wood or rubber). Based on this recent OpE, along with past OpE of through-wall liner ETE-NA-2016- Discussion in corrosion due to embedded material, are there any plans 0069 Attachment 2 (pg. to supplement the required IWL inspections to address 3 of 7) embedded materials?
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| 3 Procedure ER- 3.5.7 The Note before step 3.5.7 states that quantitative AA-CII-101, measurements are recorded and trended for applicable Revision 4 parameters monitored or inspected. There is no guidance on how this is done. Please explain how this trending is accomplished.
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| 4 NAPS Cont. IWL 5.10.1 Section 5.10.1 of the ISI-plan (Section 3.5.9 and 3.5.10 in Plan the implementing procedure) discuss evaluations that are conducted on results that do not meet the acceptance criteria and on inaccessible areas. Provide one or two recent examples of this completed evaluation. Please upload to the portal if possible.
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| SLRA Section B2.1.31 - ASME Section XI, Subsection IWF
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.31 B-214 NAPS SLRA B2.1.31 as enhanced claims consistency to GALL-SLR XI.S3. The scope of program, program element includes anchor bolts. Section 3.1.2 of Revision 1 of the AMP basis document does not indicate any exceptions to AMP Program Element 1, scope of program. CR 373274 and CR 395483 as outlined in ePortal Structures Monitoring OpE Detail Evaluations, however, state [t]his (CR) relates to base plate anchor bolt and thus not in the scope of IWF. Discuss the exclusion of anchor bolts from the scope of program program element noted in the CRs and whether this constitutes an exception to GALL-SLR AMP XI.S3.
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| 2 The CR 395483 (as described in Structures Monitoring OpE evaluations) states 2 anchor bolt nuts on top of base plate do not seat tightly to base plate. The
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| SLRA Section B2.1.31 - ASME Section XI, Subsection IWF
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| # SLRA Section SLRA Page Question / Issue described anchor bolts are HILTI-KWIK Bolts. Several ePortal documents state that NAPS Unit 1/Unit 2 use HILTI-Kwik Bolt II/Kwik Bolt 3 (KB3). Procedure GMP-M-150, Fabrication and Installation of Safety Related/Seismic/Fire Protection Supports and Structures, Revision 17, provides torqueing instruction for the HILTI-Kwik Bolt II/Kwik Bolt 3 anchor bolts.
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| ePortal NA-12-00106, Design Modification, lists HILTI adhesive anchors as an option to anchor safety-related SSCs.
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| Rules of inspection and Testing of Components of Light-Water-Cooled Plants, to ASME Code Section XI, Subsection IWA states that it is the owners responsibility to maintain a quality assurance program consistent with NQA-1/10 CFR 50 Appendix B. The HILTI Volume 2:
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| Anchor Fastening Technical Guide, 2011 edition, identifies KB3 to be a post-installed torque-controlled expansion anchor. HILTI catalog Anchor Systems identifies solely undercut anchors to be manufactured consistent with ASME NQA-1 and 10 CFR 50 App. B.
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| The catalog does not list HILTI-Kwik Bolt II/ Kwik Bolt 3 to be ASME NQA-1/10 CFR 50 App. B compliant.
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| Discuss the type of HILTI post-installed anchors used in nuclear steam supply system/IWF supports, their compliance to NQA-1/10 CFR 50 Appendix B, and whether adhesive anchors are considered an option anchoring safety-related SSCs. Provide in ePortal NAPS procedures for managing the effects of aging for such post-installed anchors.
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| 3 Underperforming equipment/support concrete anchors often are replaced with new post-installed anchors.
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| Installation of these, if used in IFW supports, need to follow manufacturers specifications. IN-2010-11 (ML090830184) addresses installation and performance issues for such anchors. Provide in ePortal NAPS procedures for installing post-installed anchors.
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| 4 AMP B2.1.31 OpE Summary 5 states that all six of each Units reactor vessel RV sliding feet were inspected in 2011. CR 448934 discusses nondestructive examinations (NDEs) performed that included magnetic particle examinations to identify potential cracks on Unit 1 sliding foot (B cold leg). ETE-SLR-2020-2418, NAPS SLR Project - Position Paper, Lubrite Aging Effects Due to Irradiation, discusses Unit 1 magnetic particle examination and states that [s]imilarly, in 2011, inspections were performed on all six of the Unit 2 reactor vessel sliding feet supports. Considering ALARA, it is not clear how these examinations were performed (e.g.,
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| in person, remotely, sliding feet removed) to assess and evaluate RV sliding feet for cracks and ascertain their continuous functionality to safe operation. It is also not
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| SLRA Section B2.1.31 - ASME Section XI, Subsection IWF
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| # SLRA Section SLRA Page Question / Issue clear whether magnetic particle examination was performed on all of Unit 2 sliding feet.
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| SLRA Section B2.1.32 - 10 CFR Part 50, Appendix J
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.32 B-220 Appendix 1 to NAPS AMP Program evaluation Report/ETE-SLR-2020-2337 Rev 1, Attachment 1 includes supplementary AMPs to manage the effects of aging than those listed in SLRA B2.1.32 for excluded from leakage testing components 2 ePortal lists AMP relevant procedures for Units 1 and 2.
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| Although these procedures for Units 1 and 2 have the same titles, they have different revision numbers. Are the two containments substantially different to require unique 10 CFR Part 50, Appendix J testing procedures?
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| SLRA Section B2.1.33 - Masonry Walls
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.33 B-224 In the NAPS Subsequent License Renewal Project -
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| AMP Evaluation Report - Masonry Walls (ETE-SLR-2020-2338, Rev. 0), Sections 3.5 and 3.6 state Evaluation criteria for masonry walls are based on the judgement of a qualified structural engineer (Ref: ER-NA-INS-104,Rev. 10, Attachment 8, Section 13.0.A).
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| However, the statement regarding the evaluation criteria for masonry walls is not found in the referenced document. Please clarify the evaluation criteria for masonry walls?
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| 2 B2.133 B-224 In the NAPS Subsequent License Renewal Project -
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| AMP Evaluation Report - Masonry Walls (ETE-SLR-2020-2338, Rev. 0), Sections 3.5 and 3.6 states Acceptance criteria for inspections ensure that observed aging effects will not impact the masonry wall intended function or potentially invalidates its evaluation basis (Ref: ER-NA-INS-104, Rev. 10, Attachment 8, Section 7.0). However, the referenced document lists the acceptance criteria for concrete and steel structures, but it does not list the acceptance criteria for masonry walls.
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| Please clarify the acceptance criteria for masonry walls (including cracks and gaps between the supports and masonry walls) and its basis?
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| SLRA Section B2.1.34 - Structures Monitoring Program (SMP)
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.34 B-230 Enhancement No. 3 states that aluminum and stainless steel components will be monitored for cracking.
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| However, it is not clear if loss of material is going to be monitored by the program. Note that associated components in SLRA Tables 3.5.2-X state that the Structures Monitoring will manage both aging effects, but the enhancement only credits one of them.
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| SLRA Section B2.1.34 - Structures Monitoring Program (SMP)
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| # SLRA Section SLRA Page Question / Issue 2 B2.1.34 B-227 Describe what the acceptance criteria are within the Structures Monitoring Program when loose bolts and nuts are identified.
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| The staff notes that SRP-SLR recommends identified loose bolts and nuts are not acceptable unless accepted by an engineering evaluation.
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| 3 B2.1.34 B-227 Clarify if NAPS has a dewatering system and what is its function. If so, how and what program manages the system?
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| 4 Table 3.5.1 3-799 Table 1 item 3.5.1-093 states that they are managed under 3.5.1.092. In general, clarify if galvanize steel is considered under general steel within the SLRA. (similar to 3.5.1-095) 5 Table 3.5.2-15 3-837, 3-890 Several Components with Note E are expected to be Table 3.5.2-38 managed by the SMP:
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| Valve Body (including frame for sluice gate valve) and other Piping and Piping Components from the Flood Protection Dike (Table 3.5.2-15, P. 3-837)
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| Spring hangers; guides; stops (Table 3.5.2-38, P. 3-890)
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| However, no enhancement was identified to include these components to the scope of the SMP. Please, clarify 6 B2.1.34 B-231 Describe in more detail the 9th operating experience listed in the OpE Summary of the program regarding the Spent Fuel Pool telltale leakage. What were the results of the borescope inspections? What actions are in place to ensure the drain lines remains open?
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| 7 B2.1.34 B-231 CR 1139921 describes a 6 ft by 7 ft concrete delamination in the SWPH due to corroded reinforcement.
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| Please, describe the issue and the actions taken. Have similar degradation been identified in other locations?
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| 8 B2.1.34 B-231 CR 408586 lists a large number of CRs involving continued groundwater in leakage and leaching (including calcium build-up) into the Unit 1 and 2 Safeguards Valve Pit. Additionally, there are many CRs related to water intrusion into structures across the site (e.g., CR 541179 (fuel building), CR 1035983 (Unit 2 cable tunnel),
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| CR 1056932 (Unit 2 turbine building Pipe Tunnel),
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| CR 555439 (Unit 2 cable vault), CR 562192 (TB basement), CR 539685/CR 519258 service water, CR 1050106 (Fire Pump House), CR 1079045 (Unit 2 Cooling Water Tunnel), CR 1086885 (Pipe penetration 67, and many more). Need to describe how the program has been identifying these issues, how they are being managed and what corrective actions has been taken.
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| SLRA Section B2.1.35 - RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants
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| # SLRA Section SLRA Page Question / Issue 1 B2.1.35 B-235
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| ==Background:==
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| B2.1.11 B-79 NUREG 2191, XI.S7, Inspection of Water-Control Structures, Parameters Monitored or Inspected states, Further details of parameters monitored or inspected are specified in Section C of RG 1.127. For reservoirs, RG 1.127, Section C notes that the program should include sedimentation.
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| NUREG-2191, Section IX.E, Aging Effects, defines Loss of material, loss of form as In earthen water-control structures, loss of material and loss of form can result from erosion, settlement, sedimentation, frost action, waves, currents, surface runoff, and seepage.
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| SLRA Section B2.1.35 states that the Inspection of Water-Control Structures program will be consistent with GALL XI.S7 after enhancements. SLRA B2.1.35 also states there are no exceptions and the two enhancements do not involve sedimentation of the reservoir.
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| Issue:
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| SLRA Table 3.5.2-31, Service Water Reservoir, identifies several AMR items that cite loss of form (which could address sedimentation in the reservoir); and it refers to Table 1 item 3.5.1-058, which lists loss of form due to erosion, settlement, sedimentation, frost action, waves, currents, surface runoff, seepage.
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| However, the list of implementing documents for AMP B2.1.35 (provided in portal document ETE-SLR-2020-2340, Rev 0, Aging Management Program Evaluation Report - Inspection of Water Control Structures Associated with Nuclear Power Plants), does not include procedure 0 PT-75.22, Service Water Sludge Depth Measurement. In addition, SLRA Section B2.1.35 and documentation provided on the portal describing the associated program does not address sedimentation in the reservoir.
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| Procedure 0-PT-75.22 includes an LR designation (so it appears to be credited for SLR), and it is included in list of implementing documents for the Open-Cycle Cooling Water System (SLRA Section B2.1.11). However, SLRA Section B2.1.11 and the associated program evaluation report on the portal (ETE-SLR-2020-2314, Rev 2) does not discuss reservoir sedimentation, and there is no associated AMR item with loss of form citing the Open-Cycle Cooling Water AMP. Typically, the Open-Cycle Cooling Water program addresses piping and heat exchanger components, although the associated
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| SLRA Section B2.1.35 - RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants
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| # SLRA Section SLRA Page Question / Issue guidance in Generic Letter 89-13, Action 1 does include intake structure inspections for fouling and Action III discusses ensuring that silting [seems like it would include sediment] cannot degrade the performance of systems supplied by service water.
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| It is not clear how this aging effect of sedimentation in Service Water Reservoir is managed.
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| 2 B2.1.35 B-235 Procedure 0-PT-75.22 Service Water Sludge Depth B2.11 B-79 Measurement shows four locations where the sludge depth is measured in the SW reservoir. These sampling locations are relatively remote from the numerous 1-inch and 2-inch drains on the reservoir spray piping (shown in Procedure 0-PT-75.11, SW Reservoir Components).
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| There is a significant amount of current OpE, indicating that substantial corrosion products (sufficient in size to clog the 1-inch drain lines) are being internally generated in the service water system. It is not obvious that the estimated amount of sludge using the current locations conservatively considers corrosion products that will stay in the immediate vicinity of spray piping drains or flushing locations.
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| Do the current sludge sample locations adequately consider corrosion product debris accumulation that is being deposited in the SW reservoir beneath the spray piping drains or near points where the spray piping is being periodically flushed?
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| SLRA Section B2.1.37 - Electrical Insulation for Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements
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| # SLRA Section SLRA Page Question / Issue 1 Under Detection of Aging Effects, Dominion states that the program performs a plant walkdown of in-scope structures to visually inspect for accessible cables and connections located in an adverse localized environment.
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| Should an adverse localized environment be observed, accessible electrical cables and connections installed in that environment are visually inspected for aging mechanism associated with jacket surface and connection covering material anomalies such as embrittlement, discoloration, cracking, melting, swelling, or surface contamination. During the teleconference call with Dominion Energy on October 22, 2020, the applicant informed the staff that there are two cables at NAPS that have fire retardant wrap. Visual inspection of cables that have fire retardant wrap around them are not adequate because these cables are not accessible. Describe inspection techniques for material conditions of cables covered with fire retardant. Can the Detection of Aging Effects program element be revised accordingly?
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| SLRA Section B2.1.39 - Electrical Insulation for Inaccessible Medium-Voltage Power Cable Not Subject to 10 CFR 50.49 Environmental Qualification Requirements
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| # SLRA Section SLRA Page Question / Issue 1 The staff reviewed the manhole inspection photographs provided by Dominion and noted what appears to be medium-voltage cables entering and exiting electrical manholes. Some of them seem to be sealed with a sealant material at the entry/exit points. Explain:
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| : 1. How are you managing water accumulation inside the raceways from one manhole to the other?
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| : 2. Are there watertight conduits connecting them or are there other forms of raceways that could be susceptible to water intrusion? If there are any raceways susceptible to water intrusion, any water penetrating in that raceway could be trapped and the cable would be permanently submerged. How do you age manage these cables?
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| SLRA Section B2.1.44 - Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements
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| # SLRA Section SLRA Page Question / Issue 1 NAPS uses Conax connectors throughout the plant (ref:
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| CR 326320). Are Conax connectors in the electrical connections program sampling basis as a separate category?
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| 2 NAPS uses lugged terminals throughout the plant (ref:
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| CR 353471). Are lugged terminals in the electrical connections program sampling basis as a separate category?
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| SLRA Section B2.1.45 - High-Voltage Insulators
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| # SLRA Section SLRA Page Question / Issue 1 Are there any photos of polymer insulators posted in the portal? If not, is it possible to provide photographs indicating material conditions?
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| 2 Are there any wooden poles utilized on the in-scope transmission lines?
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| 3 Can a complete copy of CR 582753 and CR 1023876 be provided?
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| SLRA Section B3.1 - Fatigue Monitoring Program
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| # SLRA Section SLRA Page Question / Issue 1 B3.1 B-278 through B- Associated with the Scope of Program and Parameters 283 Monitored/Inspected program elements:
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| 4.3 All SLRA Section B3.1 states The program verifies the continued acceptability of existing analyses through cycle counting. The program assures that the number of occurrences of each critical transient remains within the limits of the fatigue analyses, which in turn ensure that the analyses remain valid.
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| Several TLAAs in SLRA Section 4.3 are dispositioned in accordance with 10 CFR 54.21(c)(1)(iii), and generally
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| SLRA Section B3.1 - Fatigue Monitoring Program
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| # SLRA Section SLRA Page Question / Issue state in order to ensure the design cycles remain bounding in the fatigue analyses, the Fatigue Monitoring program (B3.1) will track cycles for significant fatigue transients listed in Table 4.3.1-1 and ensure corrective action is taken prior to potentially exceeding fatigue design limits.
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| The staff noted CN-SDA-II-18-007 and WCAP-18503-P include several more transients than those listed in SLRA Table 4.3.1-1. For example, the transients listed in Table 2-2, 2-4, 2-5 and 2-6 of CN-SDA-II-18-007 were noted.
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| GALL-SLR states the program monitors all applicable plant transients that cause cyclic strains and contribute to fatigue, as specified in the fatigue analyses, and monitors or validates appropriate environmental parameters that contribute to Fen values. The number of occurrences and the severity of the plant transients that contribute to the fatigue analyses for each component are monitored.
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| If these additional transients were considered in the fatigue TLAAs being dispositioned in accordance with (iii),
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| it would seem appropriate that these transients are also monitored by the Fatigue Monitoring Program.
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| Explain the transients being monitored by the Fatigue Monitoring Program - if they dont include ALL transients in the fatigue analyses that are dispositioned in accordance with (iii) - explain why?
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| o Based on the current procedures, it seems that many of the transients are not currently monitored. How will the AMP in the SPEO be impacted since the TLAAs are dispositioned in accordance with (iii)?
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| Related Question - Associated with Enhancement related to the Appendix L evaluations o Confirmation - Are all the transients in the Appendix L evaluations within scope of the Fatigue Monitoring Program and going to be monitored? If its only a subset, please explain why.
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| The SLRA indicates all transients in the Appendix L evaluations will be monitored -
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| however the SLRA also indicated that all transients from the fatigue analyses were going to be monitored.
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| o Confirmation - is there only one set of action limits based on fatigue analyses and the Appendix L analyses that are used to trigger corrective actions 2 4.3.1 LRA Table 4.3.1- The applicant stated that the following transients are not 1 monitored because [t]here are no cycles projected cycles
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| SLRA Section B3.1 - Fatigue Monitoring Program
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| # SLRA Section SLRA Page Question / Issue since there are no plans to perform any of these test conditions.
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| Turbine roll test Primary-Side Hydrostatic Test Secondary Side Hydrostatic Test Primary-side leak test o Are these Test Conditions procedurally prohibited, such that if the plan changes in the future that the potential monitoring of these test condition transients will be evaluated?
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| The following test conditions were not mentioned in the SLRA but were in CN-SDA-II-18-007:
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| Relief piping hydrostatic test Secondary side leak test o These were in Table 2-4 and 2-5 of CN-SDA-II-18-007, respectively, as not being monitored.
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| Are these transients procedurally prohibited, such that if the plan changes in the future that the potential monitoring of this transient will be evaluated.
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| Are there any other transients that are NOT listed in SLRA Table 4.3.1-1 that fall into this category of
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| [t]here are no cycles projected cycles since there are no plans to perform any of these test conditions.
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| o If yes, rationale/basis for not monitoring - Are these transients procedurally prohibited, such that if the plan changes in the future that the potential monitoring of this transient will be evaluated.
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| 3 4.3.1 LRA Table 4.3.1- For the following transients, the SLRA states that they are 1 not monitored because CLB cycles are > 20 times the projected cycles.
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| Unit Loading at 5 percent of Full Power/min Unit Unloading at 5 percent of Full Power/min Nuclear power plants have historically been operated as baseload units; however, based on a number of factors, some nuclear power plants have already implemented or are considering flexible power operations (FPO) (i.e., any mode of plant operation that is not baseload). These factors include, but are not limited to, more renewable generating capacity being brought on-line and a change in market dynamics.
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| Clarify if NAPS are procedurally prohibited from operating as a load-following plant (i.e., flexible power operations), such that if the plan changes in the future due to the power generation environment that monitoring of these normal conditions transients will
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| SLRA Section B3.1 - Fatigue Monitoring Program
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| # SLRA Section SLRA Page Question / Issue be evaluated. Otherwise, the monitoring of the transient would seem appropriate.
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| Are there any other transients that are NOT listed in SLRA Table 4.3.1-1 that fall into this category of CLB cycles are > 20 times the projected cycles.
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| o If yes, rationale/basis for not monitoring - Are these transients procedurally prohibited, such that if the plan changes in the future that the potential monitoring of this transient will be evaluated.
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| SLRA Section B3.2 - Neutron Fluence Monitoring
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| # SLRA Section SLRA Page Question / Issue 1 B3.2 B-285 Observation - SLRA states Ongoing inspections of RVI components for the above radiation damage mechanisms and associated degradation thresholds are performed consistent with the PWR Vessel Internals program (B2.1.7); therefore neutron fluence monitoring for the RVI is not required.
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| GALL-SLR (program description, scope of program, detection of aging effects, etc) indicates that reactor pressure vessel (RPV) and RVI components that are subject to a neutron embrittlement TLAA or other analysis involving time-dependent neutron irradiation are included in the program.
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| SLRA states that the program is consistent with GALL-SLR.
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| The SLRA and the program basis document indicate that screening thresholds and evaluation were performed to determine applicable aging effects for RVI components were performed. This appears to be an exception to the GALL-SLR.
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| SLRA Section B3.2 - Neutron Fluence Monitoring Program
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| # SLRA Section SLRA Page Question / Issue 1 B3.2 B-285 Observation - SLRA states Ongoing inspections of RVI components for the above radiation damage mechanisms and associated degradation thresholds are performed consistent with the PWR Vessel Internals program (B2.1.7); therefore, neutron fluence monitoring for the RVI is not required.
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| GALL-SLR (program description, scope of program, detection of aging effects, etc) indicates that RPV and RVI components that are subject to a neutron embrittlement TLAA or other analysis involving time-dependent neutron irradiation are included in the program.
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| SLRA Section B3.2 - Neutron Fluence Monitoring Program
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| # SLRA Section SLRA Page Question / Issue SLRA states that the program is consistent with GALL-SLR.
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| The SLRA and the program basis document indicate that screening thresholds and evaluation were performed to determine applicable aging effects for RVI components were performed. This appears to be an exception to the GALL-SLR.
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| Informing applicant - so they are not surprised about the staff-identified exception.
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| This is similar to the Surry SLRA and Neutron Fluence Monitoring AMP.
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| SLRA Section B3.3 - Environmental Qualification of Electric Equipment
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| # SLRA Section SLRA Page Question / Issue 1 The licensee cited EPRI Report NP-1558, A Review of Aging Theory and Technology, dated September 1980 as a reference under industry guidance in ETE-SLR-2019-2303, North Anna Subsequent License Renewal Project - Aging Management Program Evaluation Report
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| - Environmental Qualification of Electric Equipment, Revision 1. EPRI recently updated this report (July 2020) due to issues/concerns with lack of or expired technical references for certain activation energies. The NRC staffs understanding is that this revision resulted in up to 30 percent of activation energies being removed from the database.
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| For environmentally qualified (EQ) components that the licensee used/relied upon EPRI Report NP-1558 as the justification/basis for activation energies for extending the qualified life of EQ equipment, has the licensee reviewed this revised document to verify that their justification/basis for activation energies remains valid for EQ components for the requested period of operation?
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| 2 In ETE-SLR-2019-2303, the licensee stated that in-scope accessible passive EQ electrical equipment is inspected at least every 10 years to identify EQ electrical equipment subjected to an adverse localized environment with the first inspection to be performed prior to the subsequent period of extended operation. Additionally, the licensee noted that EQ documents that affect the qualified life of EQ components may be revised as a result of changes in field conditions identified through the corrective action program or OpE, or as a result of design changes or plant modifications that affect environmental zone boundaries or parameters.
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| Describe how NAPS considers the potential impact on EQ of electrical equipment as a result of periodic design changes/modifications to the plant.
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| SLRA Table 3.5.1 - AMR Line Items Associated with Inaccessible Concrete
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| # SLRA Section SLRA Page Question / Issue 1 SLRA Table 3.5.1 SLRA pdf 1226 of SLRA Table 3.5.1 notes that the aging effects of concrete 5803 freeze-thaw (Table 1 items 3.5.1-11, 3.5.1-42, 3.5.1-49) and concrete leaching (Table 1 items: 3.5.1-14, 3.5.1-47, 3.5.1-51) in inaccessible areas are not applicable based on the associated FEs, and the associated NUREG-2191 aging items are not used.
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| Based on the FEs, the staff understands why the applicant does not believe a plant-specific AMP or enhancement is necessary for these line items; however, the staff does not understand how the FE demonstrates the aging effects are not applicable. It appears these line items should be treated in a similar fashion as the aggregate reaction (Table 1 items: 3.5.1-12, 3.5.1-43, 3.5.1-50) items, which were identified as applicable, but the FE determined that no plant-specific enhancement or plant-specific AMP was necessary. However, the aggregate reaction line items still reference the standard AMP (e.g., SMP) that was credited in the FE for opportunistic inspections and/or evaluation of inaccessible areas based on conditions found in accessible areas.
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| Please explain how it was determined that the aging effects of freeze-thaw and concrete leaching were not applicable for inaccessible concrete.
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| In other words, provide a sufficient basis to justify absence of the aging effect in inaccessible areas given that NAPS is in a severe weathering zone, there is significant OpE of leaching at the site, and the SLRA determined aging effects of freeze-thaw and leaching are applicable in accessible areas.
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| Topics Supplemented by Virginia Electric and Power Company As a Result of Regulatory Audit Breakouts By {{letter dated|date=February 4, 2021|text=letter dated February 4, 2021}} (ADAMS Accession No. ML21035A303), Dominion Energy supplemented their SLRA for the following topics:
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| No. Topic Supplemented
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| : 1. Service Water System: Intended Function Correction
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| : 2. Heating & Ventilation System: AMR Corrections
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| : 3. Fire Protection System: Section 2.3.3.42 Clarification
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| : 4. Service Building: AMR Correction - Section 2.4.1.29 and Table 3.5.2-29
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| : 5. Reactor Coolant System: AMR Table 3.1.2-3 Clarifications
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| : 6. Chemical & Volume Control System: AMR Table 3.3.2-19 Correction (Flow element)
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| : 7. Chemical & Volume Control System: AMR Table 3.3.2-19 Correction (Orifice)
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| : 8. Emergency Diesel Generator System: Aging Management Program Change - Section 3.3.2.1.40 and AMR Table Corrections
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| : 9. Fire Protection System: Section 3.3.2.1.42 and AMR Table Corrections (Material and Environment)
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| : 10. Fire Protection System: Section 3.3.2.1.42 and AMR Table Corrections (Components on SLR boundary drawing)
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| : 11. Component Cooling System: FER and AMR Additions for Recurring Internal Corrosion
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| : 12. Component Cooling System: AMR Table 3.3.2-12 Correction (Orifice)
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| : 13. Condensate System: Aging Management Program Change - Sections 3.4.2.1.6, Table 3.4.1, and Table 3.4.2-6
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| : 14. FER 3.5.2.2.1.6, Cracking Due to Stress Corrosion Cracking: Information for aging management of stainless steel blind flanges and bolting associated with Containment electrical penetrations Added
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| : 15. FER 3.5.2.2.2.6, Reduction of Strength and Mechanical Properties of Concrete due to Irradiation: Fluence data for sliding foot assemblies Added and Editorial Correction to Table 1
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| : 16. FER 3.6.2.2.3, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections: Connection material and inspections Clarified
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| : 17. TLAA Environmentally-Assisted Fatigue Editorial Correction (Section 4.3.4) and Unit 1 and Unit 2 Appendix L Inspection Tables Updated (Tables 4.3.4-4 and 4.3.4-5)
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| : 18. TLAA Reference Editorial Correction (Section 4.8) for PWROG-19047-P, Revision 0 Attachment 2 to Enclosure
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| : 19. Leak-Before-Break Editorial Correction (A3.7.3) for WCAP-11163, Revision 2
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| : 20. ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program (B2.1.1),
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| Reactor Head Closure Stud Bolting program (B2.1.3), and ASME Section XI Subsection IWF program (B2.1.31): Unit 2 Fifth Interval 10-Year Inservice Inspection Plan
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| : 21. PWR Vessel Internals program (B2.1.7): Enhancement 1b Updated and Enhancement 2 Deleted
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| : 22. Open-Cycle Cooling Water System program (B2.1.11): Operating Experience #1 Updated
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| : 23. Fire Protection program (B2.1.15): RCP oil collection system Deleted from the Program Description
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| : 24. Fire Water System program (B2.1.16): Enhancement 5 and Enhancement 7 Revised
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| : 25. Outdoor and Large Atmospheric Metallic Storage Tanks program (B2.1.17): Program Revised to incorporate coating inspections, Exception 2, Enhancement 3, and UFSAR Supplement Revised
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| : 26. Fuel Oil Chemistry program (B2.1.18): Program Revised to incorporate coating inspections, Enhancements 1 and 4 Completed, Enhancement 2 Revised, Operating Experience #6 Updated and UFSAR Supplement Revised
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| : 27. Selective Leaching program (B2.1.21): Program Description Updated with clarification on the consistency of soil corrosivity
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| : 28. ASME Code Class 1 Small-Bore Piping program (B2.1.22): Operating Experience #7 Updated
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| : 29. Buried and Underground Piping and Tanks program (B2.1.27): Enhancement 3 Added
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| : 30. Internal Coatings/Linings for in-Scope Piping, Piping Components, Heat Exchangers, and Tanks program (B2.1.28): Program Revised for tanks inspected by other programs, Enhancement 1 Revised, Exception 1 Revised, Exception 2 Added, and UFSAR Supplement Revised
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| : 31. ASME Section XI, Subsection IWE program (B2.1.29): Program Description Clarification, Enhancements 1 and 2 Revised, Operating Experience #11 Added, and UFSAR Supplement Revised
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| : 32. ASME Section XI, Subsection IWF program (B2.1.31): Enhancement 4 Completed
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| : 33. Inspection of Water-Control Structures Associated with Nuclear Power Plants program (B2.1.35):
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| Use of Service Water Reservoir horizontal drains as a preventive measure Added to the Program Description
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| : 34. Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program (B2.1.39): Enhancements 2 through 7 Completed
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| : 35. Freeze-thaw and leaching of calcium hydroxide and carbonation aging effects require aging management for concrete in inaccessible areas of structures: AMR Tables Updated
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| ML21036A060 *concurrence via email OFFICE PM:NRLP:DNRL LA:NRLP:DNRL BC:NPHP:DNRL BC:NCSG:DNRL BC:NVIB:DNRL NAME LJames* YEdmonds* MMitchell* SBloom* HGonzalez*
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| DATE 03/18/2021 03/08/2021 02/16/2021 02/11/2021 01/25/2021 OFFICE BC:ESEB:DEX BC:EENB:DEX BC:SNSB:DSS BC:NRLP:DNRL PM:NRLP:DNRL NAME JColaccino* JJohnston* SKrepel* LGibson LJames DATE 01/19/2021 01/22/2021 01/05/2021 04/01/2021 04/08/2021}}
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