ML12283A069
| ML12283A069 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna, 07200002, 07200055  |
| Issue date: | 09/27/2012 |
| From: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| 12-525 | |
| Download: ML12283A069 (12) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 27, 2012 U.S. Nuclear Regulatory Commission Serial No.12-525 Attention: Document Control Desk NLOSITJS Rev. 1 Washington, D.C. 20555-0001 Docket Nos.: 50-280, 281 50-338, 339 72-2, 16, 55, 56 License Nos.: DPR- 32, 37 NPF- 4, 7 SNM-2501, 2507 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 AND ISFSls SURRY POWER STATION UNITS I AND 2 AND ISFSIs PROPOSED EMERGENCY ACTION LEVEL REVISIONS By letter dated October 6, 2011 and in accordance with the provisions of 10 CFR 50.90, Virginia Electric and Power Company (Dominion) submitted a license amendment request to change the Emergency Action Levels (EALs) for North Anna Power Station (NAPS) and Surry Power Station (SPS).
The purpose of this letter is to withdraw the original request and resubmit a more limited request that supersedes the original license amendment request. This resubmitted license amendment request proposes changes, which were included in the letter dated October 6, 2011, to the applicable System Malfunctions EAL to include a 15-minute threshold for RCS leaks.
The changes require prior approval by the NRC before implementation under the provisions of 10 CFR 50.54(q) because they introduce a deviation as defined in Regulatory Issue Summary 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels," Revision 4, dated January 2003, Supplement 2, dated December 12, 2005. That is, an EAL is altered such that classification of the event could be different than the site-specific EAL approved by the NRC and documented in an NRC Safety Evaluation Report (SER); in this case, NRC's SER dated February 4, 2008.
These changes to the license amendment request were discussed with NRC staff on May 9, 2012 and June 27, 2012. Attachment 1 provides a summary of and justification for the remaining proposed EAL change.
The proposed change does not involve a Significant Hazards Consideration pursuant to the provisions of 10 CFR 50.92. The proposed change has also been reviewed by each station's Facility Safety Review Committee. This change has been discussed with and LI *,
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Page 2 of 3 agreed to by the Commonwealth of Virginia and local governmental authorities in the risk jurisdictions around NAPS and SPS.
Dominion requests that review of this request be performed by September 13, 2013.
Upon receipt of approval of the proposed change, we will revise the EALs for NAPS and SPS to implement the revised classification criteria within 120 days.
If you have any questions or require additional information, please contact Mr. David Sommers at (804) 273-2823.
Sincerely, Daniel G. Stoddard Senior Vice President - Nuclear Operations COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Daniel G. Stoddard who is Senior Vice President - Nuclear Operations, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this 4 O-"*"day of , 2012.
My Commission Expires: "a..'ý. 31, 2.01 .
W--ANDA D CRAFT..
1 Notary Public iJ . p.
Commonwealth of Virginia Notary Public Reg. # 7520495 My Commission Expires January 31, 20.Lkr Attachments: : Proposed Emergency Action Level Revisions and Justification : EAL Comparison and Summary of Differences/Deviations : NAPS EAL Technical Bases Document (clean) : NAPS EAL Technical Bases Document (redline) : SPS EAL Technical Bases Document (clean) : SPS EAL Technical Bases Document (redline)
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Page 3 of 3 Commitments (Stated or Implied):
On receipt of approval of the proposed change, Dominion will revise Emergency Action Levels for North Anna and Surry Power Stations to implement the revised classification criteria.
cc: U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 Ms. K. R. Cotton*
NRC Project Manager Surry U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas*
NRC Project Manager North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector*
North Anna Power Station NRC Senior Resident Inspector*
Surry Power Station
(* w/o attachments)
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 ATTACHMENT I PROPOSED EMERGENCY ACTION LEVEL REVISIONS & JUSTIFICATION NORTH ANNA AND SURRY POWER STATIONS - UNITS 1 & 2 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Attachment 1 Page 1 of 5
Background
North Anna and Surry Power Stations implemented new Emergency Action Levels (EALs) on December 28, 2008 based on NEI 99-01, Methodology for Development of Emergency Action Levels, Rev. 4. The NRC Safety Evaluation Report (SER) dated February 4, 2008 documented the Staff's rationale for accepting the new EALs for NAPS and SPS.
Discussion 10 CFR 50.54(q) allows a licensee, as a condition of its license, to "...make changes to its emergency plan without NRC approval only if the licensee performs and retains an analysis demonstrating that the changes do not reduce the effectiveness of the plan and the plan, as changed, continues to meet the requirements of Appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b) .... Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. The licensee shall submit, as specified in § 50.4, a report of each proposed change for approval." In addition,Section IV.B of Appendix E to 10 CFR 50 specifies that, if an "... emergency action level revision decreases the effectiveness of the emergency plan" the "... licensee shall submit ... request for NRC approval of the proposed emergency action level change as specified in § 50.4."
Regulatory Issue Summary 2005-02, Clarifying the Process for Making Emergency Plan Changes, dated February 14, 2005, provides a framework for determining whether a change to an emergency preparedness requirement constitutes a decrease in effectiveness. A change that would degrade the capability to perform a function or relax the time requirements of affected emergency preparedness requirements is considered a decrease in effectiveness. In addition, Regulatory Issue Summary 2003-18, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Rev. 4 dated January 2003, Supplement 2, dated December 12, 2005, provides guidance for ensuring consistency of licensee documentation for EAL changes made under 10 CFR 50.54(q).
Dominion has determined that the change being requested requires prior NRC review and approval before implementation because it introduces a deviation as defined by RIS 2003-18. That is, the EAL and/or the EAL Technical Basis Document are altered in meaning or intent, such that classification of the event could be different from the site-specific EAL previously approved by the NRC. Therefore, per recent NRC guidance, Dominion is submitting the proposed change to the NRC according to the provisions of 10 CFR 50.90. The proposed change is as follows:
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Attachment 1 Page 2 of 5 Initiating Condition (IC) SU6 IC SU6 is being changed to include a 15-minute threshold duration to preclude classification for brief and readily isolable RCS leaks. This change provides sufficient time for prompt operator actions to isolate the leak, if possible. This approach is consistent with that used for other ICs and introduces no significant risk increase to plant workers or the public. This change will result in more appropriate classifications.
The following side-by-side "Existing" and "Proposed" change for North Anna is provided for review as an example (the Surry revision is similar and can be reviewed in Attachment 6).
SU6 RCS leakage SU6 RCS leakage for 15 minutes or longer 11 2 1 3 1 41 1 2 1 1 4 SU6.1 SU6.1 Unidentified or pressure boundary leakage > 10 gpm for 15 minutes or Unidentified or pressure boundary leakage > 10 gpm longer (Note 3)
OR OR Identified leakage > 25 gpm Identified leakage > 25 gpm for 15 minutes or longer (Note 3)
Conclusion The EAL IC modification identified above constitutes a change in methodology from that addressed by NRC's SER dated February 4, 2008. This proposed change introduces a deviation as defined in Reference B. That is, an EAL is altered in meaning or intent, such that classification of the event could be different from the site-specific EAL approved by the NRC. Therefore, prior approval from the NRC is required to satisfy the conditions of 10 CFR 50.54(q) and the requirements of Appendix E, Part IV.B.
Justification The proposed change affects the North Anna and Surry Power Station Emergency Action Levels, but does not alter the requirements of the Operating License or the Technical Specifications. The change does not alter any of the assumptions used in the safety analyses, or cause any safety system parameters to exceed their acceptance limit.
Therefore, the proposed change has no adverse effect on plant safety. Additionally, the change can be made without adverse impact to plant operations or to the health and safety of the public. Based on the technical analysis performed by Dominion, the proposed change is acceptable.
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Attachment 1 Page 3 of 5 No Significant Hazards Consideration Dominion has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed change by addressing the three criteria set forth in 10 CFR 50.92(c) as discussed below.
Criterion 1:
Does the proposed amendment involve a significant increase in the probability or consequence of an accident previously evaluated?
Response: No.
The change affects the North Anna and Surry Power Station Emergency Action Levels, but does not alter any of the requirements of the Operating License or the Technical Specifications. The proposed change does not modify any plant equipment and does not impact any failure modes that could lead to an accident. Additionally, the proposed change has no effect on the consequences of any analyzed accident since the change does not affect any equipment related to accident mitigation. Based on this discussion, the proposed amendment does not increase the probability or consequence of an accident previously evaluated.
Criterion 2:
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The change affects the North Anna and Surry Power Station Emergency Action Levels, but does not alter any of the requirements of the Operating License or the Technical Specifications. It does not modify any plant equipment and there is no impact on the capability of the existing equipment to perform their intended functions. No system setpoints are being modified. No new failure modes are introduced by the proposed change. The proposed amendment does not introduce any accident initiators or malfunctions that would cause a new or different kind of accident. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Attachment 1 Page 4 of 5 Criterion 3:
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The change affects the North Anna and Surry Power Station Emergency Action Levels, but does not alter any of the requirements of the Operating License or the Technical Specifications. The proposed change does not affect any of the assumptions used in the accident analysis, nor does it affect any operability requirements for equipment important to plant safety. Therefore, the proposed change will not result in a significant reduction in the margin of safety in operation of the facility as discussed in this license amendment request.
In summary, Dominion concludes that the proposed change does not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).
Environmental Consideration Dominion has determined that the proposed change would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements. Dominion has evaluated the proposed change and has determined that the change does not involve:
I. A Significant Hazards Consideration, II. A significant change in the types or significant increase in the amounts of an effluent that may be released off site, or Ill. A significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Attachment 1 Page 5 of 5 References A. NRC SER dated February 4, 2008 (referenced Dominion Letter Serial 07-001 dated March 28, 2007, as supplemented by letters dated October 2, 2007, and January 18, 2008).
B. RIS 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels" Revision 4, dated January 2003, Supplement 2, dated December 21, 2005.
C. NEI 99-01, "Methodology for Development of Emergency Action Levels", Revision 4, dated January 2003.
D. February 22, 2008 letter from Christopher G. Miller, Deputy Director for Emergency Preparedness, Division of Preparedness and Response, Office of Nuclear Security and Incident Response to Alan Nelson, Director, Emergency Preparedness, Nuclear Generation, Nuclear Energy Institute, subject: US Nuclear Regulatory Commission Review of NEI 99-01, Rev.5, dated February 2008.
E. Letter from J. Alan Price to Document Control Desk (NRC), "Virginia Electric and Power Company North Anna Power Station Units 1 and 2 and ISFSls Surry Power Station Units 1 and 2 and ISFSIs Proposed Emergency Action Level Revisions" dated October 6,2011.
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 ATTACHMENT 2 EAL COMPARISON AND
SUMMARY
OF DIFFERENCES / DEVIATIONS NORTH ANNA AND SURRY POWER STATIONS - UNITS 1 & 2 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Attachment 2 NAPS EAL Comparison Matrix NAPS NAPS IC Wording Rev. Proposed NAPS IC Wording Difference/Deviation Justification from Previously Approved SER IC# IC#
SU6 RCS leakage SU6 RCS leakage for 15 minutes or The words "for 15 minutes or longer" have been added.
longer The 15-minute threshold was added to the IC to preclude classification of leaks that are readily isolable from the Reactor Coolant System (RCS)
NAPS NAPS NAPS EAL Wording NAPS Proposed NAPS EAL Wording Difference/Deviation Justification from Previously Approved SER EAL# EAL#
SU6.1 Unidentified or pressure boundary SU6.1 Unidentified or pressure boundary The words "for 15 minutes or longer" were added to the EAL.
leakage Oaa > 10 gpm leakage > 10 gpm for 15 minutes or longer (Note 3) The 15-minute threshold was added to the EAL to preclude OR oclassification of leaks that are readily isolable from the Reactor OR Coolant System (RCS).
Identified leakage > 25 gpm Identified leakage > 25 gpm for 15 minutes or longer (Note 3)
Note 3: The SEM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.
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Serial No.12-525 Docket Nos. 50-280,281,338,339 / 72-2,16,55,56 Attachment 2 SPS EAL Comparison Matrix SPS SPS IC Wording Rev. Proposed SPS IC Wording Difference/Deviation Justification from Previously Approved SER IC# IC#
SU6 RCS leakage SU6 RCS leakage for 15 minutes or The words "for 15 minutes or longer" have been added.
longer The 15-minute threshold was added to the IC to preclude classification of leaks that are readily isolable from the Reactor Coolant System (RCS)
SAL SPS EAL Wording EAL Proposed SPS EAL Wording Difference/Deviation Justification from Previously Approved SER EAL# EAL#
SU6.1 Unidentified or pressure boundary SU6.1 Unidentified or pressure boundary The words "for 15 minutes or longer" were added to the EAL.
leakage a > 1or 10 gpm leakage longer>(Note 10 gpm3) for 15 minutes The 15-minute threshold was added to the EAL to preclude OR classification of leaks that are readily isolable from the Reactor OR Coolant System (RCS).
Identified leakage > 25 gpm Identified leakage > 25 gpm for 15 minutes or longer (Note 3)
Note 3: The SEM should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.
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