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{{#Wiki_filter:VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 23, 2013 U.S. Nuclear Regulatory Commission                                     Serial No.:   13-007 Attention: Document Control Desk                                       NL&OS/ETS     R2 Washington, DC 20555                                                   Docket Nos.: 50-338 50-339 License Nos.: NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
{{#Wiki_filter:VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 23, 2013 U.S. Nuclear Regulatory Commission Serial No.:
NORTH ANNA POWER STATION UNITS I AND 2 CONFIRMATORY ACTION LETTER STATUS UPDATE By letter dated November 7, 2011 (Serial No. 11-520D), Dominion submitted a compilation of long-term actions to be performed in addressing the August 23, 2011 earthquake.
13-007 Attention: Document Control Desk NL&OS/ETS R2 Washington, DC 20555 Docket Nos.:
50-338 50-339 License Nos.: NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
NORTH ANNA POWER STATION UNITS I AND 2 CONFIRMATORY ACTION LETTER STATUS UPDATE By {{letter dated|date=November 7, 2011|text=letter dated November 7, 2011}} (Serial No. 11-520D), Dominion submitted a compilation of long-term actions to be performed in addressing the August 23, 2011 earthquake.
These long-term actions were reviewed and confirmed by the NRC in a Confirmatory Action Letter (CAL) dated November 11, 2011. As discussed with the NRC staff after the CAL was issued, Dominion agreed to provide periodic status updates for the long-term actions identified in the CAL. The initial update letter was submitted on May 8, 2012 and provided status of the long-term action commitment list that had actions to be completed by April 30, 2012. The attachment to this letter provides the status of those items that had actions to be completed by December 31, 2012.
These long-term actions were reviewed and confirmed by the NRC in a Confirmatory Action Letter (CAL) dated November 11, 2011. As discussed with the NRC staff after the CAL was issued, Dominion agreed to provide periodic status updates for the long-term actions identified in the CAL. The initial update letter was submitted on May 8, 2012 and provided status of the long-term action commitment list that had actions to be completed by April 30, 2012. The attachment to this letter provides the status of those items that had actions to be completed by December 31, 2012.
As discussed in a telephone call on November 20, 2012 with Ms. M. Khanna of your staff, it was agreed to coordinate the submittal of summary information regarding a leak-before-break (LBB) comparison (Item 7 in the CAL) and the inspection plan for MRP-227 (Item 8 in the CAL) with the submittal of summary information on the remaining actions in the CAL which are to be completed by April 30, 2013. Thus, a summary of the LBB analysis comparison and the MRP-227 inspection plan will be submitted with the CAL closeout letter.
As discussed in a telephone call on November 20, 2012 with Ms. M. Khanna of your staff, it was agreed to coordinate the submittal of summary information regarding a leak-before-break (LBB) comparison (Item 7 in the CAL) and the inspection plan for MRP-227 (Item 8 in the CAL) with the submittal of summary information on the remaining actions in the CAL which are to be completed by April 30, 2013. Thus, a summary of the LBB analysis comparison and the MRP-227 inspection plan will be submitted with the CAL closeout letter.
If you have any questions or require               additional information,   please contact Mr. Thomas Shaub at (804) 273-2763.
If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.
Sincerely, J. A. Price Vice President - Nuclear Engineering
Sincerely, J. A. Price Vice President - Nuclear Engineering


==Attachment:==
==Attachment:==
Status Update for Long-Term Action Commitments
Status Update for Long-Term Action Commitments


Serial Number 13-007 Docket Nos. 50-338/339 Page 2 of 2 cc: Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station Ms. M. Khanna Branch Chief - Division of Operating Reactor Licensing U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B1A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. N. L. Salgado Branch Chief - Division of Operating Reactor Licensing U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 C2A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 J. E. Reasor, Jr.
Serial Number 13-007 Docket Nos. 50-338/339 Page 2 of 2 cc:
Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station Ms. M. Khanna Branch Chief - Division of Operating Reactor Licensing U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B1A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. N. L. Salgado Branch Chief - Division of Operating Reactor Licensing U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 C2A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 J. E. Reasor, Jr.
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
Glen Allen, Virginia 23060
Glen Allen, Virginia 23060
Line 33: Line 35:
North Anna Power Station Units I and 2
North Anna Power Station Units I and 2


Serial No. 13-007 Docket Nos. 50-338/339 Attachment Page 1 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Item                                                                                               Scheduled No.                                       Commitment                                           Completion Date 1   Dominion will perform long-term evaluations of plant structures, systems and components in accordance with RG 1.167/EPRI NP-6695, Section 6.3. Any anomalies identified during the evaluations will be entered into the corrective action system and evaluated for extent of condition.
Serial No. 13-007 Docket Nos. 50-338/339 Attachment Page 1 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Item Scheduled No.
Status: Ongoing,                                                                           April 30, 2013 The In-structure Response Spectra have been developed from the recorded time histories of the August 23, 2011 earthquake for the site structures housing safety related SSCs and the evaluations of the SSCs are ongoing.
Commitment Completion Date 1
2   Dominion will develop a plan to characterize the seismic source and any special ground motion effects due to the relative locations of the fault and the site and will update the NRC accordingly.
Dominion will perform long-term evaluations of plant structures, systems and components in accordance with RG 1.167/EPRI NP-6695, Section 6.3. Any anomalies identified during the evaluations will be entered into the corrective action system and evaluated for extent of condition.
Status: The-action item for plan development has been completed. (Ongoing activities to implement the plan will be completed as indicatedbelow.).
Status: Ongoing, April 30, 2013 The In-structure Response Spectra have been developed from the recorded time histories of the August 23, 2011 earthquake for the site structures housing safety related SSCs and the evaluations of the SSCs are ongoing.
The Dominion plan to characterizethe seismic source and any special ground motion effects due to the relative locations of the fault and site is presented below.
2 Dominion will develop a plan to characterize the seismic source and any special ground motion effects due to the relative locations of the fault and the site and will update the NRC accordingly.
    'The earthquake catalog contained within the Centraland Eastern US'Seismric Source Characterization(CEUS-SSC) model and database has been updated to include the last three years of seismicity data (through mid-December 2011).
Status: The-action item for plan development has been completed. (Ongoing activities to implement the plan will be completed as indicated below.).
This update:includes the.Mw 5.8 earthquakein Louisa County Virginia. The updated earthquake catalogwas issued March.8, 2012.
The Dominion plan to characterize the seismic source and any special ground motion effects due to the relative locations of the fault and site is presented below.
'The earthquake catalog contained within the Central and Eastern US'Seismric Source Characterization (CEUS-SSC) model and database has been updated to include the last three years of seismicity data (through mid-December 2011).
This update:includes the.Mw 5.8 earthquake in Louisa County Virginia. The updated earthquake catalog was issued March.8, 2012.
Dominion has obtained data from the USGS and the Virginia Seismologic
Dominion has obtained data from the USGS and the Virginia Seismologic
      ,Observatoryat Virginia Tech on the main. shock and aftershocks resulting from.
,Observatory at Virginia Tech on the main. shock and aftershocks resulting from.
the earthquake.. The aftershocks define a planarfeature in the subsurface that           March 31, 2012 appears to be a previously unknown fault.                                                   (Complete)
the earthquake.. The aftershocks define a planar feature in the subsurface that March 31, 2012 appears to be a previously unknown fault.
: 1. Dominion is conducting a geologic reconnaissanceof the relatively linear projection of the aftershock hypocenters to the ground surface and other
(Complete)
            -featuresof significance that may be identified through -review of LiDAR' imagery obtained for a defined area of interest and field work. The objective of the LiDAR imagery review and field work is to document the presence or absence of any evidence for surface faulting due to the earthquake. The .LiDAR survey review was completed during December
: 1. Dominion is conducting a geologic reconnaissance of the relatively linear projection of the aftershock hypocenters to the ground surface and other
            .2011 and February2012, and data evaluation is.in progress. The. field" reconnaissancewas guidedbyusing maps that combine geologic data with LiDAR imagery. The field reconnaissancewas completed on April2       23, 2012: The final report was completed in May 2012.
-features of significance that may be identified through -review of LiDAR' imagery obtained for a defined area of interest and field work. The objective of the LiDAR imagery review and field work is to document the presence or absence of any evidence for surface faulting due to the earthquake. The.LiDAR survey review was completed during December
: 2. Separately, the USGS has indicatedplans to perform a geophysical survey for the.August 23, 201 event during the spring of 20,12. Dominion:will review the data obtained from that survey and incorporateany new findings
.2011 and February 2012, and data evaluation is.in progress. The. field" reconnaissance was guidedbyusing maps that combine geologic data with LiDAR imagery. The field reconnaissance was completed on April2 23, 2012: The final report was completed in May 2012.
          ..into our overall evaluation of the event.
: 2. Separately, the USGS has indicated plans to perform a geophysical survey for the.August 23, 201 event during the spring of 20,12. Dominion: will review the data obtained from that survey and incorporate any new findings
: 3. The data collected from LiDAR imagery, field reconnaissanceand geologic mapping review did not provide evidence of surface fault expression the August 23, 2011 event might have caused, or longer term, largerscale deformation relatedto seismic activity. Though readily observable                       update geologicaldeformation evidence was not found during the field reconnaissance,seismic geophysical data obtained from the numerous aftershocks revealed that the August 23, 2011 event likely originatedalong
..into our overall evaluation of the event.
: 3. The data collected from LiDAR imagery, field reconnaissance and geologic mapping review did not provide evidence of surface fault expression the August 23, 2011 event might have caused, or longer term, larger scale deformation related to seismic activity. Though readily observable update geological deformation evidence was not found during the field reconnaissance, seismic geophysical data obtained from the numerous aftershocks revealed that the August 23, 2011 event likely originated along


Serial No. 13-007 Docket Nos. 50-338/339 Attachment Page 2 of 4 Long-Term Action Commitment List North Anna Power Station Units 1 and 2 Item                                                                                         Scheduled No.                                       Commitment                                       Completion Date a previously unmapped fault estimated to be approximately 6.2 miles in length with a N 280 to 300 E strike and 450 to 510 SE dip angle. Additional investigative work by the USGS has not been completed and will be reviewed when it becomes available.
Serial No. 13-007 Docket Nos. 50-338/339 Attachment Page 2 of 4 Long-Term Action Commitment List North Anna Power Station Units 1 and 2 Item Scheduled No.
3 Dominion will revise the North Anna Updated Final Safety Analysis Report to document:
Commitment Completion Date a previously unmapped fault estimated to be approximately 6.2 miles in length with a N 280 to 300 E strike and 450 to 510 SE dip angle. Additional investigative work by the USGS has not been completed and will be reviewed when it becomes available.
3 Dominion will revise the North Anna Updated Final Safety Analysis Report to document:
ai The recorded August23, 2011 seismic event.
ai The recorded August23, 2011 seismic event.
Status: Complete         .:                                                    April 30, 2012 Section 2.7 of the UFSAR has been revised;to include a description'ofthe          (Complete)
Status: Complete April 30, 2012 Section 2.7 of the UFSAR has been revised; to include a description'of the (Complete)
August23, 2011 seismic event.
August23, 2011 seismic event.
: b. A summary of the evaluation and results of the seismic analysis of the recorded event completed per RG 1.167/EPRI NP-6695.
: b.
Status: Ongoing                                                                 April 30, 2013 The summary will be finalized and included in the UFSAR when the work/analysis activities in Item 1 are complete.
A summary of the evaluation and results of the seismic analysis of the recorded event completed per RG 1.167/EPRI NP-6695.
: c. Design controls on seismic margin management (i.e., the Seismic Margin Management Plan).*          *: : :: ~ mplte*
Status: Ongoing April 30, 2013 The summary will be finalized and included in the UFSAR when the work/analysis activities in Item 1 are complete.
                                " " tatu              :    *    *        *April         Arl3,21 30, 2012*
: c. Design controls on seismic margin management (i.e., the Seismic Margin Management Plan).
Status:ý Complete ..          . ...              *  . .    :        . v     :(Com plete)
Arl3,21 tatu ::  
Section 3.7 of the UFSAR has been revised to include a descriptionof the         (Complete Seismic Margin Management Plan..
~ mplte*  
: d. Incorporation of Regulatory Guide (RG) 1.166, "Pre-Earthquake Planning and Immediate Nuclear Power Plant Operator Post-Earthquake Actions,"
*April 30, 2012*
and RG 1.167, "Restart of a Nuclear Power Plant Shut Down by a Seismic Event," into the North Anna licensing basis.                                   December31, Status: Complete                                                                     2012 Section 3.7.4 of the UFSAR has been revised to include Dominion's               (Complete) commitment to RG 1.166 and RG 1.167.
Status:ý Complete v
4 Dominion will implement a design change to replace the existing seismic equipment and Main Control Room indication with upgraded and enhanced seismic monitoring instrumentation equipment, which includes installation of a permanent, free field seismic monitor. Permanent, seismically qualified backup power to a new Seismic Monitoring Panel will also be installed including a backup battery power supply. The seismic instrumentation will be installed and maintained in accordance with RG 1.12, Rev 2, Nuclear Power Plant Instrumentation for Earthquakes. The project will also install seismic recording           2012 instrumentation at the station Independent Spent Fuel Storage Installation (ISFSI)         2012 pad.                                                                                     (Complete)
:(Com plete)
Status: Complete New seismic instruments and associated controls/indicationwere installed in the Unit I containmentand main control room during the spring 2012 refueling outage and made functional. The remainderof the instruments (auxiliarybuilding, ISFSI and free field) were installed and consideredfunctional in November 2012.
Section 3.7 of the UFSAR has been revised to include a description of the (Complete Seismic Margin Management Plan..
: d.
Incorporation of Regulatory Guide (RG) 1.166, "Pre-Earthquake Planning and Immediate Nuclear Power Plant Operator Post-Earthquake Actions,"
and RG 1.167, "Restart of a Nuclear Power Plant Shut Down by a Seismic Event," into the North Anna licensing basis.
December 31, Status: Complete 2012 Section 3.7.4 of the UFSAR has been revised to include Dominion's (Complete) commitment to RG 1.166 and RG 1.167.
4 Dominion will implement a design change to replace the existing seismic equipment and Main Control Room indication with upgraded and enhanced seismic monitoring instrumentation equipment, which includes installation of a permanent, free field seismic monitor. Permanent, seismically qualified backup power to a new Seismic Monitoring Panel will also be installed including a backup battery power supply. The seismic instrumentation will be installed and maintained in accordance with RG 1.12, Rev 2, Nuclear Power Plant Instrumentation for Earthquakes. The project will also install seismic recording 2012 instrumentation at the station Independent Spent Fuel Storage Installation (ISFSI) 2012 pad.
(Complete)
Status: Complete New seismic instruments and associated controls/indication were installed in the Unit I containment and main control room during the spring 2012 refueling outage and made functional. The remainder of the instruments (auxiliary building, ISFSI and free field) were installed and considered functional in November 2012.


Serial No. 13-007 Docket Nos. 50-338/339 Attachment Page 3 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Item                                                                                           Scheduled No.                                     Commitment                                         Completion No.                                                                                               Date 5 Dominion will perform a re-evaluation of the plant equipment identified in the IPEEE review with HCLPF capacity <0.3g, which will include an assessment of potential improvements.
Serial No. 13-007 Docket Nos. 50-338/339 Attachment Page 3 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Item Scheduled No.
Status: Ongoing                                                                       March 31, 2013 The preliminaryre-revaluationis completed. Review and documentation of the results are being performed.
Commitment Completion No.
6   Dominion will develop a plan with the NSSS vendor consisting of additional evaluations or inspections, as warranted, to assure long term reliability of the reactor internals.
Date 5
Status: Complete Dominion Engineeringperformed a systematic review of the previous evaluations, NRC correspondence, and inspections of the reactorvessel internals (RVI) that were performed following the August 23,12011 earthquake. Data and rationalefor future planned programmaticinspectionswere consideredand,included input from             February 29, Westinghouse, the NSSS vendor. Results of the prioractivities were summarized               2012.,
Dominion will perform a re-evaluation of the plant equipment identified in the IPEEE review with HCLPF capacity <0.3g, which will include an assessment of potential improvements.
and evaluated regarding their demonstrationof RVI integrity. As a result of the           (Complete) evaluation, the: RVI remain capableof reliably performing their function in the future. Furthermore,RVI inspectionsperformed during the spring 2012,Unit 1 refueling outage did not identify any seismically induced issues. Therefore, it was concluded that.developing a plan consisting of additional inspections and.
Status: Ongoing March 31, 2013 The preliminary re-revaluation is completed. Review and documentation of the results are being performed.
evaluations of the RVI beyond:those already requiredby existing programs is not warrantedfor assuring the long term reliabilityof the RVI.
6 Dominion will develop a plan with the NSSS vendor consisting of additional evaluations or inspections, as warranted, to assure long term reliability of the reactor internals.
7   Dominion will perform a comparison of the calculated load from the August 23, 2011 earthquake and the existing leak-before-break (LBB) analysis and submit the results.
Status: Complete Dominion Engineering performed a systematic review of the previous evaluations, NRC correspondence, and inspections of the reactor vessel internals (RVI) that were performed following the August 23,12011 earthquake. Data and rationale for future planned programmatic inspections were considered and, included input from February 29, Westinghouse, the NSSS vendor. Results of the prior activities were summarized 2012.,
Status: Ongoing                                                                       March 31, 2013 A summary of the load comparison will be submitted with the final CAL close-out letter. The comparison shows that the existing licensing basis LBB analysis remains valid.
and evaluated regarding their demonstration of RVI integrity. As a result of the (Complete) evaluation, the: RVI remain capable of reliably performing their function in the future. Furthermore, RVI inspections performed during the spring 2012, Unit 1 refueling outage did not identify any seismically induced issues. Therefore, it was concluded that. developing a plan consisting of additional inspections and.
8 Dominion will perform inspections at North Anna Power Station in accordance           In accordance with the latest MRP-227 revision approved by the NRC.                                 with the MRP-Status: Ongoing                                                                       227 inspection The inspection plan has been finalized and will be submitted with the final CAL       plan, which will close-out letter.                                                                     be provided by March 31, 2013 9 Dominion will re-evaluate the Time-Limiting Aging Analyses (TLAAs) that include seismic inputs to either: 1) quantitatively demonstrate that the TLAAs are still bounding, or 2) re-analyze the TLAAs, based on the August 23, 2011 earthquake.
evaluations of the RVI beyond: those already required by existing programs is not warranted for assuring the long term reliability of the RVI.
Status: Ongoing                                                                       March 31, 2013 Seismic loads on equipment and piping subjected to the appropriatein-structure response spectra from the 8/23/11 seismic event have been extracted and tabulatedand are being compared to the seismic loads utilized in the applicable
7 Dominion will perform a comparison of the calculated load from the August 23, 2011 earthquake and the existing leak-before-break (LBB) analysis and submit the results.
Status: Ongoing March 31, 2013 A summary of the load comparison will be submitted with the final CAL close-out letter. The comparison shows that the existing licensing basis LBB analysis remains valid.
8 Dominion will perform inspections at North Anna Power Station in accordance In accordance with the latest MRP-227 revision approved by the NRC.
with the MRP-Status: Ongoing 227 inspection The inspection plan has been finalized and will be submitted with the final CAL plan, which will close-out letter.
be provided by March 31, 2013 9
Dominion will re-evaluate the Time-Limiting Aging Analyses (TLAAs) that include seismic inputs to either: 1) quantitatively demonstrate that the TLAAs are still bounding, or 2) re-analyze the TLAAs, based on the August 23, 2011 earthquake.
Status: Ongoing March 31, 2013 Seismic loads on equipment and piping subjected to the appropriate in-structure response spectra from the 8/23/11 seismic event have been extracted and tabulated and are being compared to the seismic loads utilized in the applicable


Serial No. 13-007 Docket Nos. 50-338/339 Attachment Page 4 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Scheduled Item                                     Commitment                                           Completion No.
Serial No. 13-007 Docket Nos. 50-338/339 Attachment Page 4 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Scheduled Item Commitment Completion No.
Date TLAAs. Comparisonsindicate that.the conclusions of the seismic-inducedfatigue related TLAAs of components reviewed for the License Renewal Program remain valid.
Date TLAAs. Comparisons indicate that.the conclusions of the seismic-induced fatigue related TLAAs of components reviewed for the License Renewal Program remain valid.
10 Dominion will implement a long term Seismic Margin :Management. Plan to address the impact of the August 23, 2011 earthquake. Specifically, to ensure adequate seismic margins .are maintainedfor:plant SSCs, Dominion will revise the design: changer process for North Anna Power Station to require explicit evaluation of plant modifications for the effects of the August 23, 2011 earthquake using In-Structure Response Spectra, (ISRS) for the event for the Containment, Auxiliary Building,:.and other buildings containing safety related SSCs developed based on actual: time-histories recorded during the event. In support of future plant design changes, the evaluation of plant SSCs will require design verification     December 31, and code compliance with the stresses, loads, accelerations, and displacements                 2011'.
10 Dominion will implement a long term Seismic Margin :Management. Plan to address the impact of the August 23, 2011 earthquake.
generated from the analysis with the design basis. ISRS and the analysis with the         (Complete)
Specifically, to ensure adequate seismic margins.are maintainedfor:plant SSCs, Dominion will revise the design: changer process for North Anna Power Station to require explicit evaluation of plant modifications for the effects of the August 23, 2011 earthquake using In-Structure Response Spectra, (ISRS) for the event for the Containment, Auxiliary Building,:.and other buildings containing safety related SSCs developed based on actual: time-histories recorded during the event.
ISRS for the August 23, 2011 earthquake, whichever are higher.
In support of future plant design changes, the evaluation of plant SSCs will require design verification and code compliance with the stresses, loads, accelerations, and displacements generated from the analysis with the design basis. ISRS and the analysis with the ISRS for the August 23, 2011 earthquake, whichever are higher.
Status: Complete The:Nuclear Design ControlProgram has been revised to incorporatecontrols that will ensure that seismic margin is maintained at North Anna Power.Station.for plant modificationsperformed after the August 23,2011 earthquake.
Status: Complete The:Nuclear Design Control Program has been revised to incorporate controls that will ensure that seismic margin is maintained at North Anna Power.Station. for plant modifications performed after the August 23,2011 earthquake.
i Dominion will provide 30-days prior written notification to the NRC if it determines the Seismic Margin Management Plan is no longer required based on the implementation of comparable actions as part of the resolution of the NRC's                     N/A recommendations emanating from the Fukushima Daiichi Task Force and/or Generic Issue (GI)-199.
December 31, 2011'.
The shaded items were previously reported in a letter dated May 8, 2012 (Serial 12-235).}}
(Complete)
Dominion will provide 30-days prior written notification to the NRC if it determines the Seismic Margin Management Plan is no longer required based on the implementation of comparable actions as part of the resolution of the NRC's recommendations emanating from the Fukushima Daiichi Task Force and/or Generic Issue (GI)-199.
i N/A The shaded items were previously reported in a {{letter dated|date=May 8, 2012|text=letter dated May 8, 2012}} (Serial 12-235).}}

Latest revision as of 11:26, 11 January 2025

Confirmatory Action Letter, Status Update
ML13032A078
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 01/23/2013
From: Price J
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13032A078 (7)


Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 23, 2013 U.S. Nuclear Regulatory Commission Serial No.:

13-007 Attention: Document Control Desk NL&OS/ETS R2 Washington, DC 20555 Docket Nos.:

50-338 50-339 License Nos.: NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS I AND 2 CONFIRMATORY ACTION LETTER STATUS UPDATE By letter dated November 7, 2011 (Serial No. 11-520D), Dominion submitted a compilation of long-term actions to be performed in addressing the August 23, 2011 earthquake.

These long-term actions were reviewed and confirmed by the NRC in a Confirmatory Action Letter (CAL) dated November 11, 2011. As discussed with the NRC staff after the CAL was issued, Dominion agreed to provide periodic status updates for the long-term actions identified in the CAL. The initial update letter was submitted on May 8, 2012 and provided status of the long-term action commitment list that had actions to be completed by April 30, 2012. The attachment to this letter provides the status of those items that had actions to be completed by December 31, 2012.

As discussed in a telephone call on November 20, 2012 with Ms. M. Khanna of your staff, it was agreed to coordinate the submittal of summary information regarding a leak-before-break (LBB) comparison (Item 7 in the CAL) and the inspection plan for MRP-227 (Item 8 in the CAL) with the submittal of summary information on the remaining actions in the CAL which are to be completed by April 30, 2013. Thus, a summary of the LBB analysis comparison and the MRP-227 inspection plan will be submitted with the CAL closeout letter.

If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.

Sincerely, J. A. Price Vice President - Nuclear Engineering

Attachment:

Status Update for Long-Term Action Commitments

Serial Number 13-007 Docket Nos. 50-338/339 Page 2 of 2 cc:

Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station Ms. M. Khanna Branch Chief - Division of Operating Reactor Licensing U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B1A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. N. L. Salgado Branch Chief - Division of Operating Reactor Licensing U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 C2A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Glen Allen, Virginia 23060

Serial No.13-007 Docket Nos. 50-338/339 Attachment Status Update for Long-Term Action Commitments Virginia Electric and Power Company (Dominion)

North Anna Power Station Units I and 2

Serial No.13-007 Docket Nos. 50-338/339 Attachment Page 1 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Item Scheduled No.

Commitment Completion Date 1

Dominion will perform long-term evaluations of plant structures, systems and components in accordance with RG 1.167/EPRI NP-6695, Section 6.3. Any anomalies identified during the evaluations will be entered into the corrective action system and evaluated for extent of condition.

Status: Ongoing, April 30, 2013 The In-structure Response Spectra have been developed from the recorded time histories of the August 23, 2011 earthquake for the site structures housing safety related SSCs and the evaluations of the SSCs are ongoing.

2 Dominion will develop a plan to characterize the seismic source and any special ground motion effects due to the relative locations of the fault and the site and will update the NRC accordingly.

Status: The-action item for plan development has been completed. (Ongoing activities to implement the plan will be completed as indicated below.).

The Dominion plan to characterize the seismic source and any special ground motion effects due to the relative locations of the fault and site is presented below.

'The earthquake catalog contained within the Central and Eastern US'Seismric Source Characterization (CEUS-SSC) model and database has been updated to include the last three years of seismicity data (through mid-December 2011).

This update:includes the.Mw 5.8 earthquake in Louisa County Virginia. The updated earthquake catalog was issued March.8, 2012.

Dominion has obtained data from the USGS and the Virginia Seismologic

,Observatory at Virginia Tech on the main. shock and aftershocks resulting from.

the earthquake.. The aftershocks define a planar feature in the subsurface that March 31, 2012 appears to be a previously unknown fault.

(Complete)

1. Dominion is conducting a geologic reconnaissance of the relatively linear projection of the aftershock hypocenters to the ground surface and other

-features of significance that may be identified through -review of LiDAR' imagery obtained for a defined area of interest and field work. The objective of the LiDAR imagery review and field work is to document the presence or absence of any evidence for surface faulting due to the earthquake. The.LiDAR survey review was completed during December

.2011 and February 2012, and data evaluation is.in progress. The. field" reconnaissance was guidedbyusing maps that combine geologic data with LiDAR imagery. The field reconnaissance was completed on April2 23, 2012: The final report was completed in May 2012.

2. Separately, the USGS has indicated plans to perform a geophysical survey for the.August 23, 201 event during the spring of 20,12. Dominion: will review the data obtained from that survey and incorporate any new findings

..into our overall evaluation of the event.

3. The data collected from LiDAR imagery, field reconnaissance and geologic mapping review did not provide evidence of surface fault expression the August 23, 2011 event might have caused, or longer term, larger scale deformation related to seismic activity. Though readily observable update geological deformation evidence was not found during the field reconnaissance, seismic geophysical data obtained from the numerous aftershocks revealed that the August 23, 2011 event likely originated along

Serial No.13-007 Docket Nos. 50-338/339 Attachment Page 2 of 4 Long-Term Action Commitment List North Anna Power Station Units 1 and 2 Item Scheduled No.

Commitment Completion Date a previously unmapped fault estimated to be approximately 6.2 miles in length with a N 280 to 300 E strike and 450 to 510 SE dip angle. Additional investigative work by the USGS has not been completed and will be reviewed when it becomes available.

3 Dominion will revise the North Anna Updated Final Safety Analysis Report to document:

ai The recorded August23, 2011 seismic event.

Status: Complete April 30, 2012 Section 2.7 of the UFSAR has been revised; to include a description'of the (Complete)

August23, 2011 seismic event.

b.

A summary of the evaluation and results of the seismic analysis of the recorded event completed per RG 1.167/EPRI NP-6695.

Status: Ongoing April 30, 2013 The summary will be finalized and included in the UFSAR when the work/analysis activities in Item 1 are complete.

c. Design controls on seismic margin management (i.e., the Seismic Margin Management Plan).

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(Com plete)

Section 3.7 of the UFSAR has been revised to include a description of the (Complete Seismic Margin Management Plan..

d.

Incorporation of Regulatory Guide (RG) 1.166, "Pre-Earthquake Planning and Immediate Nuclear Power Plant Operator Post-Earthquake Actions,"

and RG 1.167, "Restart of a Nuclear Power Plant Shut Down by a Seismic Event," into the North Anna licensing basis.

December 31, Status: Complete 2012 Section 3.7.4 of the UFSAR has been revised to include Dominion's (Complete) commitment to RG 1.166 and RG 1.167.

4 Dominion will implement a design change to replace the existing seismic equipment and Main Control Room indication with upgraded and enhanced seismic monitoring instrumentation equipment, which includes installation of a permanent, free field seismic monitor. Permanent, seismically qualified backup power to a new Seismic Monitoring Panel will also be installed including a backup battery power supply. The seismic instrumentation will be installed and maintained in accordance with RG 1.12, Rev 2, Nuclear Power Plant Instrumentation for Earthquakes. The project will also install seismic recording 2012 instrumentation at the station Independent Spent Fuel Storage Installation (ISFSI) 2012 pad.

(Complete)

Status: Complete New seismic instruments and associated controls/indication were installed in the Unit I containment and main control room during the spring 2012 refueling outage and made functional. The remainder of the instruments (auxiliary building, ISFSI and free field) were installed and considered functional in November 2012.

Serial No.13-007 Docket Nos. 50-338/339 Attachment Page 3 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Item Scheduled No.

Commitment Completion No.

Date 5

Dominion will perform a re-evaluation of the plant equipment identified in the IPEEE review with HCLPF capacity <0.3g, which will include an assessment of potential improvements.

Status: Ongoing March 31, 2013 The preliminary re-revaluation is completed. Review and documentation of the results are being performed.

6 Dominion will develop a plan with the NSSS vendor consisting of additional evaluations or inspections, as warranted, to assure long term reliability of the reactor internals.

Status: Complete Dominion Engineering performed a systematic review of the previous evaluations, NRC correspondence, and inspections of the reactor vessel internals (RVI) that were performed following the August 23,12011 earthquake. Data and rationale for future planned programmatic inspections were considered and, included input from February 29, Westinghouse, the NSSS vendor. Results of the prior activities were summarized 2012.,

and evaluated regarding their demonstration of RVI integrity. As a result of the (Complete) evaluation, the: RVI remain capable of reliably performing their function in the future. Furthermore, RVI inspections performed during the spring 2012, Unit 1 refueling outage did not identify any seismically induced issues. Therefore, it was concluded that. developing a plan consisting of additional inspections and.

evaluations of the RVI beyond: those already required by existing programs is not warranted for assuring the long term reliability of the RVI.

7 Dominion will perform a comparison of the calculated load from the August 23, 2011 earthquake and the existing leak-before-break (LBB) analysis and submit the results.

Status: Ongoing March 31, 2013 A summary of the load comparison will be submitted with the final CAL close-out letter. The comparison shows that the existing licensing basis LBB analysis remains valid.

8 Dominion will perform inspections at North Anna Power Station in accordance In accordance with the latest MRP-227 revision approved by the NRC.

with the MRP-Status: Ongoing 227 inspection The inspection plan has been finalized and will be submitted with the final CAL plan, which will close-out letter.

be provided by March 31, 2013 9

Dominion will re-evaluate the Time-Limiting Aging Analyses (TLAAs) that include seismic inputs to either: 1) quantitatively demonstrate that the TLAAs are still bounding, or 2) re-analyze the TLAAs, based on the August 23, 2011 earthquake.

Status: Ongoing March 31, 2013 Seismic loads on equipment and piping subjected to the appropriate in-structure response spectra from the 8/23/11 seismic event have been extracted and tabulated and are being compared to the seismic loads utilized in the applicable

Serial No.13-007 Docket Nos. 50-338/339 Attachment Page 4 of 4 Long-Term Action Commitment List North Anna Power Station Units I and 2 Scheduled Item Commitment Completion No.

Date TLAAs. Comparisons indicate that.the conclusions of the seismic-induced fatigue related TLAAs of components reviewed for the License Renewal Program remain valid.

10 Dominion will implement a long term Seismic Margin :Management. Plan to address the impact of the August 23, 2011 earthquake.

Specifically, to ensure adequate seismic margins.are maintainedfor:plant SSCs, Dominion will revise the design: changer process for North Anna Power Station to require explicit evaluation of plant modifications for the effects of the August 23, 2011 earthquake using In-Structure Response Spectra, (ISRS) for the event for the Containment, Auxiliary Building,:.and other buildings containing safety related SSCs developed based on actual: time-histories recorded during the event.

In support of future plant design changes, the evaluation of plant SSCs will require design verification and code compliance with the stresses, loads, accelerations, and displacements generated from the analysis with the design basis. ISRS and the analysis with the ISRS for the August 23, 2011 earthquake, whichever are higher.

Status: Complete The:Nuclear Design Control Program has been revised to incorporate controls that will ensure that seismic margin is maintained at North Anna Power.Station. for plant modifications performed after the August 23,2011 earthquake.

December 31, 2011'.

(Complete)

Dominion will provide 30-days prior written notification to the NRC if it determines the Seismic Margin Management Plan is no longer required based on the implementation of comparable actions as part of the resolution of the NRC's recommendations emanating from the Fukushima Daiichi Task Force and/or Generic Issue (GI)-199.

i N/A The shaded items were previously reported in a letter dated May 8, 2012 (Serial 12-235).