ML032540402

Amendments 236 & 235 to Licenses DPR-32 & DPR-37, Respectively. Amendments Revise Technical Specifications to Add Provisions to Permit Inspections & Related Repair of Buried Fuel Oil Storage Tank During Plant Operation

ML032540402
Person / Time
Site:	Surry
Issue date:	09/10/2003
From:	Gratton C NRC/NRR/DLPM/LPD2
To:	Christian D Virginia Electric & Power Co (VEPCO)
Gratton C, NRR/DLPM, 415-1055
References
TAC MB6291, TAC MB6292
Download: ML032540402 (18)

Text

September 10, 2003 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711

SUBJECT:

SURRY UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS FOR THE EMERGENCY DIESEL GENERATOR BURIED FUEL OIL STORAGE TANKS (TAC NOS.

MB6291 AND MB6292)

Dear Mr. Christian:

The Commission has issued the enclosed Amendment No. 236 to Renewed Facility Operating License No. DPR-32 and Amendment No. 235 to Renewed Facility Operating License No. DPR-37 for the Surry Power Station, Unit Nos. 1 and 2, respectively. The amendments change the Technical Specifications (TS) in response to your application transmitted by letter dated September 5, 2002, as supplemented by letters dated April 16, June 9, and July 7, 2003.

These amendments revise the technical specifications to add provisions to permit inspection and related repair of a buried fuel oil storage tank during plant operation.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Christopher Gratton, Sr. Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281

Enclosures:

1. Amendment No. 236 to DPR-32

2. Amendment No. 235 to DPR-37

3. Safety Evaluation cc w/encls: See next page

ML032540402 Distribution: See next page OFFICE PM:PDII-1 LA:PDII-2 SPSP SPLB OGC SC:PDII-1 NAME CGratton EDunnington MReinhart DSolorio DCummings JNakoski DATE 8/13/03 8/13/03 8/22/03 8/20/03 5/5/03 9/10/03 DATED: September 10, 2003 AMENDMENT NO. 236 TO FACILITY OPERATING LICENSE NO. DPR SURRY UNIT 1 AMENDMENT NO. 235 TO FACILITY OPERATING LICENSE NO. DPR SURRY UNIT 2 PUBLIC PDII Rdg.

E. Dunnington C. Gratton E. Hackett J. Nakoski OGC G. Hill (4), TWFN, 5/C/3 ACRS K. Landis, RII J. Tatum J. Schiffgrens

VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-280 SURRY POWER STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 236 Renewed License No. DPR-32

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Virginia Electric and Power Company (the licensee) dated September 5, 2002, as supplemented by letters dated April 16, June 9, and July 7, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Renewed Facility Operating License No. DPR-32 is hereby amended to read as follows:

(B) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 236, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

John A. Nakoski, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 10, 2003

VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-281 SURRY POWER STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 235 Renewed License No. DPR-37

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Virginia Electric and Power Company (the licensee) dated September 5, 2002, as supplemented by letters dated April 16, June 9, and July 7, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Renewed Facility Operating License No. DPR-37 is hereby amended to read as follows:

(B) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 235, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

John A. Nakoski, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 10, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 236 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-32 LICENSE AMENDMENT NO. 235 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-37 DOCKET NOS. 50-280 AND 50-281 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages TS 3.16-2 TS 3.16-2 TS 3.16-3 TS 3.16-3 TS 3.16-6 TS 3.16-6

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 236 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-32 AND AMENDMENT NO. 235 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-280 AND 50-281

1.0 INTRODUCTION

By letter dated September 5, 2002, as supplemented by letters dated April 16, June 9, and July 7, 2003, Virginia Electric and Power Company (VEPCO, or the licensee) submitted a license amendment request to revise the Technical Specifications (TS) of Surry Power Station, Units 1 and 2. The proposed changes include a revision of TS Limiting Condition for Operation (LCO) 3.16, Electrical Power Systems, to permit inspection and related repair of the buried fuel oil storage tanks for the emergency diesel generators (EDGs) during plant operation.

2.0 REGULATORY EVALUATION

2.1 Regulatory Basis VEPCO has requested a change to the TS allowed outage time (AOT) for the EDG buried fuel oil storage tanks. The regulatory bases for specific TS AOT values consist primarily of regulatory policy and practice as reflected in the Standard Technical Specification (STS)

Requirements. As discussed in the licensees submittal, such a precedent was approved by the Nuclear Regulatory Commission (NRC) staff for the North Anna Power Station, Units 1 and 2, on July 3, 1990. Finally, the licensees amendment request includes both risk and traditional engineering considerations and, therefore, the guidance provided in Standard Review Plan (SRP) Chapter 16.1, Risk-Informed Decisionmaking: Technical Specifications, and in Regulatory Guide (RG) 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications, are applicable. Acceptance of the licensees request will be judged based on these considerations.

2.2 System Description

The Surry Power Station has three EDGs for the two units. One EDG is dedicated to each of the units and the remaining EDG is shared between the units. Each EDG has an independent day tank (combined auxiliary wall tank and base tank) with sufficient capacity for at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

of full-load operation. The auxiliary wall tanks are filled by transferring fuel oil from either one of the two buried safety-related, seismic Category 1, tornado-missile-protected fuel oil storage tanks, each having a 20,000-gallon capacity. The minimum-required combined inventory of the two buried fuel oil storage tanks (35,000 gallons) will support the full-load operation of one EDG for at least 7 days. The buried fuel oil storage tanks are gravity-fed from the 210,000-gallon non-safety-related above ground fuel oil storage tank. The two buried and one above ground fuel oil storage tanks are common to both of the Surry units. In addition to these onsite sources of fuel oil, three above ground non-safety-related storage tanks that typically contain a combined inventory of about 3,000,000 gallons of fuel oil are located adjacent to the Surry Power Station at Dominions Gravel Neck Combustion Turbine Facility. In accordance with the Surry Hurricane Response Plan, measures are in place to obtain backup fuel oil from Gravel Neck for the Surry buried fuel oil storage tanks using the onsite 1200-gallon station tanker truck.

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, Application for amendment of a license or construction permit, the licensee has requested a change to TS 3.16 to add provisions that will permit inspection and repair of the buried fuel oil storage tanks during plant operation. General industry experience indicates that periodic inspection of buried fuel oil storage tanks is prudent. However, the tanks must be removed from service and emptied to facilitate inspection and repair activities. The existing Surry TS requirements would require a dual unit outage in order to permit inspection and repair of a buried fuel oil storage tank. Consequently, in order to allow inspection and repair of the buried fuel oil storage tanks at Surry, VEPCO has proposed the following revisions to TS 3.16:

1. TS 3.16.B.1.b will be revised to permit the currently allowed 24-hour AOT for one diesel fuel oil flow path inoperable to be exceeded by revising the second sentence in TS 3.16.B.1.b to read: If after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the inoperable flow path cannot be returned to service for reasons other than buried fuel oil storage tank inspection and related repair, the diesel shall be considered INOPERABLE.

2. TS 3.16.B.4 will be added to include the following new requirements for a buried fuel oil storage tank taken out of service for inspection and related repair:

One buried fuel oil storage tank may be inoperable for 7 days for tank inspection and related repair, provided that the following actions are taken:

a. prior to removing the tank from service, verify that 50,000 gallons of replacement fuel oil is available offsite and transportation is available to deliver that volume of fuel oil within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, and

b. prior to removing the tank from service and at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, verify that the remaining buried fuel oil storage tank contains $ 17,500 gallons, and

c. prior to removing the tank from service and at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, verify that the above ground fuel oil storage tank contains $ 50,000 gallons.

If these conditions are not satisfied or if the buried fuel oil storage tank is not returned to OPERABLE status within 7 days, both units shall be placed in HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

3. The following discussion will be added in the TS 3.16 Basis as the second paragraph on page TS 3.16-6:

One of the two buried fuel oil storage tanks may be inoperable to permit inspection and related repair of that buried fuel oil storage tank. While one tank is removed from service, the remaining buried fuel oil storage tank supplies fuel oil to the EDGs of both units. Prior to removal of one buried tank from service and while it is inoperable, verification of the volume in the remaining buried fuel oil storage tank and the above ground fuel oil storage tank is required to ensure an adequate source of fuel oil remains available onsite. In addition, verification of the offsite replacement fuel oil supply is also required. While one buried tank is out of service, the verification of the onsite and offsite fuel oil sources continues to support full load operation of one diesel generator for 7 days.

In support of the proposed changes to TS 3.16, the licensee has proposed the following commitments in order to assure availability of the EDGs in the event of adverse conditions:

• Provisions to obtain fuel from Gravel Neck using the station tanker truck will be verified prior to a buried fuel oil tank being removed from service.

• Planning and scheduling activities to remove a buried fuel oil tank from service will specifically identify restrictions/contingency measures.

• Fuel transfer pump operability will be verified prior to removing a buried fuel oil storage tank from service.

• The implementing procedure(s) for buried fuel oil tank inspection activities will specify that arrival of the first tanker truck will be within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following identification of the need for the offsite replacement fuel oil.

• The implementing procedure(s) for buried fuel oil tank inspection activities will specify that the out-of-service tank will be returned to an available status in an expeditious manner if a hurricane or severe thunderstorm/tornado condition is impending or in the event that EDG operation is required while a buried tank is out of service.

With respect to the licensees commitment to identify restrictions/contingency measures for removing a buried fuel oil tank from service, the April 16, 2003, submittal indicated that VEPCO planning and scheduling documentation will identify the following restrictions/contingency measures:

• A buried fuel oil tank will not be taken out of service with a severe weather forecast for the area.

• Station switchyard activities and other electrical maintenance that could cause any unstable offsite or onsite power conditions will not be scheduled while a buried fuel oil tank is out of service.

• The Alternate AC Diesel Generator (AADG) will be operable prior to removing a buried fuel oil tank from service.

• Provisions to obtain fuel from the Gravel Neck facility using the station tanker truck will be verified prior to removing a buried fuel oil tank from service.

3.0 EVALUATION 3.1 Deterministic Evaluation In addition to the EDG day tanks, the two buried fuel oil storage tanks are credited as the assured safety-related sources of fuel oil for the Surry EDGs. As described in Section 8.5 of the Surry Updated Final Safety Analysis Report, sufficient fuel oil must be available from the EDG day tanks and the buried fuel oil storage tanks to support operation of a fully loaded EDG for 7 days. This minimum-required onsite fuel oil supply is considered to be sufficient to allow replenishment from outside sources before the onsite supply is fully depleted, thereby assuring safe shutdown capability following events and anticipated operational occurrences (AOOs) that involve a concurrent loss-of-offsite-power (LOOP) condition. The combined fuel oil inventory from both of the safety-related underground fuel oil storage tanks is necessary to satisfy this provision of the EDG design basis for the Surry units.

It is important to note that the Surry EDG design basis is different from the EDG design basis of a Standard Technical Specification (STS) plant in that the EDG fuel oil storage tanks at Surry are shared among all three EDGs, while a STS plant has separate fuel oil storage tanks for each EDG. Not only does Surry not have separate fuel oil storage tanks for each of the three EDGs, the two fuel oil storage tanks at Surry are shared between the two Surry units.

Therefore, removing one of the two safety-related fuel oil storage tanks from service at Surry affects both units and all three EDGs at the same time. For this particular condition, Surry TS 3.16 specifies a 24-hour AOT while the STS would allow a 72-hour AOT. Such a situation at Surry represents a severely degraded condition and any extension of the AOT must include special provisions to assure that the EDGs will be able to perform their design-basis safety function.

As discussed above in Section 2.2 of this evaluation, the licensee has proposed additional TS requirements, commitments, contingency measures, and restrictions to assure the continued capability of the Surry EDGs when planning to take one of the buried safety-related fuel oil storage tanks out of service for inspection and repair. In short, these provisions:

• establish multiple sources of readily available fuel oil reserves prior to removing a buried safety-related fuel oil storage tank from service for inspection and repair,

• provide assurance that fuel oil for the EDGs will be replenished before the safety-related onsite inventory is depleted even when relying on delivery of fuel oil by tanker trucks from a remote location,

• assure operability of the AADG prior to removing a buried fuel oil tank from service,

• restrict the removal of a buried fuel oil tank from service and requires its restoration when severe weather is forecast for the area or if there is a need for EDG operation, and

• restrict the performance of electrical maintenance activities that could cause any unstable offsite or onsite power conditions.

The proposed TS requirements, commitments, contingencies, and restrictions maintain defense-in-depth through implementation of programmatic activities. The NRC staff finds that the TS requirements and other provisions that are proposed by VEPCO are appropriate and sufficient to assure that the Surry EDGs will be able to perform their design-basis safety function during periods when one of the buried safety-related fuel oil storage tanks is removed from service for inspection and repair. Because the design-basis safety function of the EDGs will be assured during the proposed 7-day AOT, the Surry accident analyses and safety margins are not affected by the proposed change. The NRC staff agrees that periodic inspection and repair of the buried fuel oil storage tanks are necessary in order to maintain and confirm the structural integrity of the tanks. Currently, these inspections and repairs can only be done during a dual-unit outage. Therefore, the NRC staff finds that inspection and repair of the buried fuel oil storage tanks can be done safely during power operation and that the proposed TS change is reasonable.

The 7-day AOT that VEPCO has proposed for this condition is consistent with a similar North Anna AOT discussed above in Section 2.1 and approved by the NRC in an evaluation dated July 3, 1990. A 7-day AOT that is invoked about once every 10 years for each of the two buried fuel oil storage tanks allows sufficient time for the licensee to complete necessary inspections and repairs of the buried fuel oil storage tanks, while at the same time limiting reliance on the proposed programmatic activities to an acceptably short period and is consistent with what was approved for North Anna.

3.2 Risk Assessment The licensee qualitatively and quantitatively analyzed the risks associated with the proposed TS change and associated maintenance activities using RG 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, and RG 1.177.

With regard to RG 1.174, the licensee plans to make use of the provisions of the proposed TS AOT extension to 7 days only once, for each buried tank, every 10 years. Consequently, the increase in the test and maintenance unavailability for the fuel oil supply system has a negligible impact on the average core damage and large early release frequencies (CDF and LERF, respectively). Using the current Surry probabilistic risk assessment (PRA) model, the average internal events CDF and LERF were estimated to be 2.97E-05 per year and 8.36E-07 per year, respectively. As stated in RG 1.174, for CDFs and LERFs of these magnitudes, the NRC staff considers the increases acceptably small if the increases are less than 1E-05 per year and 1E-06 per year, respectively. The licensee estimates the increase in average CDF to be less than 2.0E-08 per year and the increase in average LERF to be less than 1.6E-10 per year.

With regard to RG 1.177, Tier 1, the licensee estimated the minimum risk of operation during the LCO for which a buried fuel oil storage tank is out of service for the proposed AOT. The internal events CDF and LERF were estimated to be 3.02E-05 per year and 8.40E-07 per year, respectively, for operation during the AOT, resulting in an incremental conditional core damage probability (ICCDP) of 9.8E-09 and an incremental conditional large early release probability

(ICLERP) of 8.2E-11. As stated in RG 1.177, for a single TS AOT change, the NRC staff considers an ICCDP of less than 5.0E-07 and an ICLERP of less than 5.0E-08 acceptably small. The risk impact of a buried fuel oil storage tank out of service is small due to extensive redundancy in the emergency power supply system (Surry has a swing EDG, an EDG, and an AADG with an independent source of fuel oil) and the EDG fuel oil supply system. The licensee points out that EDG failures and unavailability, due to any cause, contribute only 3.1 percent to the total CDF, and LOOP and station blackout events contribute only 0.6 percent and 2.0 percent, respectively. Prior to entering the LCO for maintenance on one of the buried fuel oil storage tanks, the licensee will verify that fuel oil from the other tank is available to all three EDGs and that the AADG is operable.

In addition, the licensee discussed external events, in particular, earthquakes, severe weather, and internal fires. In each case, the licensee showed qualitatively that reasonable precautions are being taken and that the risk from such events during the proposed AOT is acceptably small. The possibility of maintenance-induced fires was also discussed and the steps to be taken to minimize fire risks, in addition to those contained in VPAP-2401, Fire Protection Program and VPAP-1904, Confined Space Entry Program, are acceptable to the NRC staff.

Tier 2 of RG 1.177 is concerned with identification of potentially high risk configurations that could exist if equipment in addition to that associated with the change were to be taken out of service simultaneously, or other risk-significant operational factors such as concurrent system or equipment testing were also involved. The licensee performed a bounding analysis to demonstrate the robustness of the emergency AC power supply system and the small risk of the proposed maintenance even in the event of the loss of other risk-significant equipment, by estimating the conditional CDF and LERF during a LOOP for comparison with the conditional CDF and LERF during a LOOP while the plant is in an LCO for tank maintenance. The results show that even for a 7-day period, the ICCDP and ICLERP during a LOOP would only be 6.0E-7 and 4.6E-9, respectively, levels which the NRC staff would consider small. If one buried fuel oil tank was out of service at the same time, the ICCDP and ICLERP would only increase by 3.0E-07 and 4.0E-9, respectively. Again, increases of this magnitude are considered small by the NRC staff. These limiting cases do not reflect plant operating experience or practices; only that the licensee has satisfactorily considered other risk-significant operational factors and met Tier 2 objectives. It should be noted that the LOOP event frequency for Surry is expected to be less than 0.027 per year because station switchyard activities and other electrical maintenance that could cause unstable offsite or onsite power conditions will not be scheduled while a buried fuel tank is out of service.

Tier 3 of RG 1.177 is concerned with the licensees program and/or procedures that ensure that the risk impact of out-of-service equipment is appropriately evaluated prior to performing any maintenance activity. According to the licensee, the Surry 10 CFR 50.65 (a)(4) program meets the guidance in RG 1.177 Tier 3, Risk-Informed Configuration Management, making it acceptable for managing risks associated with risk-informed TS changes. The documents used by various groups at Surry for managing their portion of the risk management program are: (1) Operations Administrative Procedure OPAP-0006, Shift Operating Practices, Section 6.13, Risk Management at Power; (2) Outage and Planning Administrative Procedure DNAP-2000, Dominion Work Management Process, Attachment 7, On-line Maintenance Risk Assessment Factors; (3) Outage and Planning Administrative Procedure PLAP-2000, Supplement Work Management Process, Section 6.13, On-line Maintenance Risk

Assessment; and (4) Station Safety and Licensing Administrative Procedure SEAP-0002, Shift Technical Advisor, Section 6.6, Risk Management.

The NRC staff did not review the licensees PRA model or the details of the analysis outlined in the amendment request. However, the licensee was asked to perform various calculations, the results of which, considered together with quantitative results presented with the amendment request, indicate that the PRA model is adequate for analysis of the risks associated with the proposed TS change. Based on the licensees quantitative and qualitative analysis, the NRC staff concludes that the risks associated with entering the proposed TS LCO for an extended AOT of 7 days approximately every 10 years is acceptably small.

3.3 Evaluation Summary The NRC staff has determined, based on the considerations discussed above, that the proposed changes to TS 3.16 are necessary and appropriate, and that defense-in-depth and safety margins are maintained by the proposed TS requirements, commitments, contingencies, and restrictions. The NRC staff also concludes that the risks associated with entering the proposed TS LCO for an extended AOT of 7 days approximately every 10 years for each buried fuel oil storage tank is acceptably small. Therefore, with respect to the traditional engineering considerations set forth in SRP Chapter 16.1 and RG 1.177, and the risk considerations set forth in RG 1.174 and RG 1.177, the NRC staff concludes that the changes proposed to TS 3.16 are acceptable.

The licensee also made conforming changes to the TS Bases. The NRC staff has no objection to the TS Bases changes

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Virginia State official was notified of the proposed issuance of the amendments. The State official had no comment.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (68 FR 46247). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by

operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: J. Tatum, SPLB J. Schiffgens, SPSB Date: September 10, 2003

Mr. David A. Christian Surry Power Station Virginia Electric and Power Company Units 1 and 2 cc:

Ms. Lillian M.Cuoco, Esq. Office of the Attorney General Senior Counsel Commonwealth of Virginia Dominion Resources Services, Inc. 900 East Main Street Millstone Power Station Richmond, Virginia 23219 Building 475, 5th Floor Rope Ferry Road Mr. Chris L. Funderburk, Director Rt. 156 Nuclear Licensing & Operations Support Waterford, Connecticut 06385 Virginia Electric and Power Company Innsbrook Technical Center Mr. Richard H. Blount, II 5000 Dominion Blvd.

Site Vice President Glen Allen, Virginia 23060-6711 Surry Power Station Virginia Electric and Power Company Mr. David A. Heacock 5570 Hog Island Road Site Vice President Surry, Virginia 23883-0315 North Anna Power Station Virginia Electric and Power Company Senior Resident Inspector P. O. Box 402 Surry Power Station Mineral, Virginia 23117-0402 U. S. Nuclear Regulatory Commission 5850 Hog Island Road Mr. William R. Matthews Surry, Virginia 23883 Vice President - Nuclear Operations Virginia Electric and Power Company Chairman Innsbrook Technical Center Board of Supervisors of Surry County 5000 Dominion Boulevard Surry County Courthouse Glen Allen, Virginia 23060-6711 Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation P. O. Box 1197 Richmond, Virginia 23209 Robert B. Strobe, M.D., M.P.H.

State Health Commissioner Office of the Commissioner Virginia Department of Health P.O. Box 2448 Richmond, Virginia 23218