ML061000741
| ML061000741 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/07/2006 |
| From: | Grecheck E Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 06-200 | |
| Download: ML061000741 (6) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY
- RICHMOND, VIRGINIA 23261 1 OCFR50.92 A p r i l 7, 2006 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Serial No.06-200 NL&OS/GDM R4 Docket Nos. 50-280 License Nos. DPR-32 50-281 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE REDEFINITION OF EXCLUSION AREA BOUNDARY RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated September 13, 2005 (Serial No.05-601), Virginia Electric and Power Company (Dominion) requested amendments to the Operating Licenses for Surry Power Station Units 1 and 2 to redefine the exclusion area boundary (EAB) as the site boundary in the Technical Specifications (TS). The redefined EAB will significantly reduce the design basis accident Atmospheric Dispersion Factor (X/Q), which will consequently reduce the calculated EAB dose consequences for Updated Safety Analysis Report Chapter 14 accidents in future reanalyses. In a letter dated February 22, 2006, the NRC requested additional information to facilitate their review.
Specifically, the NRC requested: 1) confirmation of Dominions authority to control various activities associated with the redefined EAB, and 2) justification for why Regulatory Guide 1.145 methodology was not used to determine the minimum distances from potential release points to the EAB in each wind direction. Dominions response to these two questions is provided in the attachment.
If you have any questions or require additional information regarding this TS change request, please contact Mr. Gary Miller at (804) 273-2771.
Very truly yours, U
E. S. Grecheck Vice President - Nuclear Support Services Attachment
Serial No.06-200 Docket Nos. 50-280, 281 Page 2 of 2 Commitment made in this letter:
Dominion will provide the NRC recalculated EAB WQs and minimum sector distances based on RG 1.I45 by May 31,2006.
cc:
U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. N. P. Garrett NRC Senior Resident Inspector Surry Power Station Mr. S. R. Monarque NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 1 1555 Rockville Pike Mail Stop 8-HI 2 Rockville, MD 20852 Commissioner Bureau of Radiological Health 1500 East Main Street Suite 240 Richmond, VA 2321 8
Serial No.06-200 Docket Nos. 280,281
Subject:
TS Change Request RAI-Redefinition of EAB COMMONWEALTH OF VIRGINIA
)
1 COUNTY OF HENRICO
)
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck, who is the Vice President -
Nuclear Support Services of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the forgoing document in behalf of that Company, and that the statements in the document are true and correct to the best of his knowledge, information, and belief.
Acknowledged before me this 7 day of $a3.:p
,2006.
My Commission Expires: J\\h aonb.
Notary Public (SEAL)
Serial No.06-200 Docket Nos. 50-280, 281 ATTACHMENT ProDosed Technical SDecifications Chanae Redefinition of Exclusion Area Boundary ResDonse to Reauest for Additional Information By letter dated September 13, 2005, Virginia Electric and Power Company (Dominion) submitted proposed license amendments for Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2). These proposed changes would redefine the exclusion area boundary (EAB) as the site boundary in Technical Specification 5.1, Site.
NRC Question No. I The proposed redefinition of the Surry I and 2 EAB from an area bounded by a 1650-foot radius centered at the Surry 1 reactor containment building to the site boundary will change the shape and increase the size of the EAB from approximately 0.79 square kilometers (196 acres) to 3.36 square kilometers (840 acres). Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 100. I I(a), the Surry Power Station site must have an exclusion area, which is defined in 10 CFR 100.3 as an area surrounding the reactor in which the reactor licensee has the authority to determine all activities, including the exclusion or removal of personnel and property from the area.
The exclusion area may be traversed by a highway (e.g., State Route 650); provided that it is not so close to the facility as to interfere with normal operations of the facility and provided appropriate and effective arrangements are made to control traffic on the highway, in case of emergency, to protect the public health and safety. Consequently, please confirm the following for the proposed new and larger EAB:
- a. VEPCO has the authority to control activities within the revised EAB, including the exclusion and removal of personnel and property.
- b. VEPCO has total control over access to the revised EAB, except for the public access on State Route 650 to the Hog Island State Wildlife Management Area.
- c. No activities unrelated to plant operations (other than transit through the area) are permitted in the revised EAB without VEPCO's approval.
- d. State Route 650 is sufficiently distant from plant structures so that routine use of this route is not likely to interfere with normal plant operation.
- e. Provisions have been made for controlling traffic entering and leaving the revised EAB on State Route 650 in the event of an emergency. Please also describe these pro visions.
Dominion ResDonse For items a-d above, Dominion hereby confirms that it has: 1) the authority to control activities within the revised Exclusion Area Boundary (EAB), including the exclusion and removal of personnel and property, and 2) total control over access to the revised EAB, except for the public access on State Route 650 to the Hog Island State Wildlife Management Area. Furthermore, no activities unrelated to plant operations (other than transit through the area) are permitted in the revised EAB without Dominion's approval.
Also, State Route 650 is sufficiently distant from plant structures so that routine use of Page 1 of 3
Serial No.06-200 Docket Nos. 50-280, 281 Attachment this route is not likely to interfere with normal plant operation.
Regarding item e, Surry Power Station has measures in place for controlling traffic entering and leaving the revised EAB on State Route 650 in the event of an emergency.
Specifically, Surry Emergency Plan Implementing Procedure (EPIP) 5.04, Access Control, is implemented by Station Protection Services to ensure that only personnel with an emergency response function have access to the site. This procedure is initiated upon declaration of an Alert or higher emergency classification or when deemed necessary by the Station Emergency Manager. Visitors are notified to leave the site, and assistance is requested from local law enforcement agencies (LLEAs) to establish a road block. Site access is limited to offsite emergency response vehicles and emergency response personnel.
Letters of Agreement (LOA) are also maintained with offsite agencies supporting traffic control in the area around Surry Power Station. For example, the Commonwealth of Virginia Department of Emergency Management LOA states that the Virginia Emergency Operations Center will notify the Virginia Department of Transportation to establish roadblocks, when appropriate. The Virginia State Police (Fifth Division) LOA states that the Virginia State Police will support enforcement of ingress/egress provision in controlled areas, when established in coordination with local officials. The Surry County Sheriff LOA states that the Sheriffs Office will enforce ingresdegress provisions, when established, in coordination with the State Police.
NRC Question No. 2 The EAB source-to-receptor distances listed in Table 1 of Attachment 1 to the September 13, 2005, submittal are proposed to be used to define the EAB by wind direction sector for future dose analyses that may be accommodated under 10 CFR 50.59. The distances in this table represent the minimum distances from potential release points for the loss-of-coolant accident and fuel-handling accident in each 22.5 wind direction sector. Regulatory Position C. 1.2 of Regulatory Guide (RG) 1.145, Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants, states that for releases through vents or building penetrations, the distances for EAB X/Q calculations should be the minimum distance from the nearest point on the building to the EAB within a 45 sector centered on each of the 16 wind direction sectors. The RG 1.145 procedure takes into consideration the possibility of curved airflow trajectories, plume segmentation during low wind and stable conditions, and the potential for wind speed and wind direction frequency shifts from year to year. Please justify why the RG 1.145 methodology was not used to determine the Table 1 minimum distances from potential release points to the EAB in each wind direction.
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Serial No.06-200 Docket Nos. 50-280, 281 Attachment Dominion ResDonse Dominion did not recognize that the minimum sector distances were not consistent with Regulatory Position C.1.2 of Regulatory Guide (RG) 1.145 when the WQ values were being prepared for the redefined EAB. New WQ values are being prepared that are consistent with the guidance provided in RG 1.145. This will enable Dominion to determine whether using source-to-receptor distances based on the RG guidance has a significant impact on the calculated WQ values previously provided in Dominion's proposed TS change request dated September 13,2005. To ensure accurate distances are being used for determining the source-to-receptor distances, the site boundary dimensions indicated on the Surry site plan drawing are being validated. Dominion will provide the recalculated EAB WQs and minimum sector distances based on RG 1.145 guidance to the NRC by May 31, 2006 to facilitate review of the Surry Technical Specifications change request.
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