ML18153B007
| ML18153B007 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 07/12/1994 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-275, NUDOCS 9407190397 | |
| Download: ML18153B007 (12) | |
Text
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VIRGINIA. ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 12, 1994 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No.
NEP/SAH Docket Nos.
License Nos.
NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED REVISION TO STATION EMERGENCY PLANS94-275 50-280 50-281 50-338 50-339 DPR-32 DPR-37 NPF-4 NPF-7 Pursuant to 10 CFR 50.54(q), Virginia Electric and Power Company hereby requests Nuclear Regulatory Commission (NRC) approval of a proposed revision to the Surry Power Station Emergency Plan and the North Anna Power Station Emergency Plan. This revision modifies an overcommitment in the surveillance requirements for emergency kits and emergency survey instrumentation. The surveillance frequency would be changed from monthly to quarterly for inventory and operational checks. The request specifically meets the intent of 10 CFR 50.47(b) through compliance with existing guidance. The proposed Plan modification is provided in Attachment 1. Attachment 2 provides the final modification as it would appear in the next Plan revision,. while Attachment 3 provides supporting justification which demonstrates our emergency response capability is maintained at an equivalent level.
This request is being submitted as part of our Cost Beneficial Licensing Actions (CBLA) program and complies with NRC guidelines for consideration as a CBLA submittal.
Please contact Mr. J. E. Collins at (804) 273-2728 if you have any questions or require additional information regarding this request.
Very truly yours, qp~
J. P. O'Hanlon Senior Vice President - Nuclear Operations
-:: C: r~. n r~.' O J;_U'U'\\Jt:.~0 9407190397 940712 PDR ADOCK 05000280 F
.PDR
cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, Ga. 30323 Mr. M. W. Branch NRG Senior Resident Inspector Surry Power Station Mr. R. D. McWhorter NRG Senior Resident Inspector North Anna Power Station
ATTACHMENT 1 PROPOSED REVISION TO SURRY POWER STATION EMERGENCY PLAN PROPOSED REVISION TO NORTH ANNA POWER STATION EMERGENCY PLAN
NOTE:
Section 7.3.2 Section 8.7 ATTACHMENT 1 Proposed revisions to the Surry and North Anna Power Station Emergency Plans are identical.
Radiological Monitoring, third paragraph, last sentence:
The kits are set aside solely for emergency use and are inventoried, and checked for calibration and operability on a monthly gµ§ff.i:ni basis.
Testing and Maintenance of Emergency Equipment b)
Dedicated emergency survey instrumentation shall be inventoried and operationally checked monthly qµJ.J.ffllrl and following m~ffi:I::::@im~ any emergency requiring tt:i"efr****Gs*a*:.....
ATTACHMENT 2 INCORPORATION OF PROPOSED REVISION INTO SURRY POWER STATION EMERGENCY PLAN INCORPORATION OF PROPOSED REVISION INTO NORTH ANNA POWER STATION EMERGENCY PLAN
e ATTACHMENT 2 SURRY POWER STATION EMERGENCY PLAN SECTION 7.3.2, PAGE 7.11:
10.7). The kits are set aside solely for emergency use and are inventoried and checked for calibration and operability on a quarterly basis.
Portable equipment is also available to take low or high volume air samples. Battery operated air samplers can be used to collect low volume samples either onsite or offsite. Silver Zeolite cartridges would be used for sampling radioiodine with a minimum detectable activity capability of 5X10-a microcuries per cc. Silver Zeolite has a low retention efficiency for Xenon and therefore, interference should be minimal. Plastic bags and bottles are available to collect water, soil, foodstuffs or other samples.
EPIPs provide the methodology for determining the magnitude of a release by three separate and independent methods: (1) using data or samples continuously obtained by the onsite Radiation Monitoring System, (2) using known inventory data for the system(s) affected, and (3) obtaining offsite data from air samplers or dosimeters which are continuously in place, or taking radiation surveys and appropriate samples, and using this data to calculate releases.
Equipment designated for use in environmental surveillance such as air samplers and theromoluminescent dosimeters (TLDs) is used to obtain offsite data. The radiological monitoring instrumentation and sampling devices used by the station meet the minimum requirements of the NRC Radiological Assessment Branch Technical Position for Environmental Radiological Monitoring Programs. Two Virginia Power TLDs have been placed in each of the accessible sectors within an approximate 5 mile radius of the station for accident monitoring. Further details can be found in VPAP-2103, "Offsite Dose Calculation Manual". The State also has TLD monitoring points located around the Station used for verification purposes. Dosimetry and air sampler locations within the 1 O mile EPZ are shown on Figures 7.1 and 7.2.
Surry maintains fixed laboratory equipment to support sampling analysis and monitoring.
The equipment includes Multichannel Analyzers, whole body counters and TLD reading processors.
7.3.3 Meteorological Monitoring The station's Meteorological Monitoring System provides the capability for making predictions of atmospheric effluent transport and diffusion. The system consists of a primary and a backup tower, the locations of which were chosen so as to be representative of regional conditions. The data which is input to the Emergency Response Facility Computer System (ERFCS) for use in the MIDAS model and which is transmitted to the Control Room and the Environmental Services Group in Richmond is derived from instrumentation located at these towers. Table 7.2 provides a listing of the parameters measured.
The meteorological equipment was designed to meet the criteria of Regulatory Guide 1.23, "On Site Meteorological Programs", dated February 1972.
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SURRY POWER STATION EMERGENCY PLAN SECTION 8.7, PAGE 8.13:
8.7 8.8 Testing and Maintenance of Emergency Equipment Emergency equipment shall be periodically tested to identify and correct deficiencies in accordance with administrative procedures.
Inventories and tests shall be documented and forwarded to Station Records.
The testing shall Include:
a)
The contents of the emergency kits dedicated for emergency use shall be inventoried quarterly and following each use. The Superintendent Radiological Protection shall ensure these test are conducted and documented.
b)
Dedicated emergency survey instrumentation shall be inventoried and operationally checked quarterly and following each use.
They shall be calibrated in accordance with manufacturer's recommendations. The Superintendent Radiological Protection shall ensure these tests are conducted and documented.
c)
Self-contained breathing apparatus shall be inspected and operationally checked monthly and following use during an emergency. The Superintendent Radiological Protection shall ensure these tests are conducted and documented.
d)
State and local ring down loop (lnsta-phone) extensions and the ringdown phone to the State EOC located at the station and LEOF shall be operationally checked on a monthly basis. In addition, NRC Emergency Notification System extensions and NRC Health Physics Network extensions located at the station and LEOF shall be operationally checked monthly.
The Station Coordinator Emergency Planning shall ensure these tests are conducted and documented.
Informing The Public Information describing the emergency notification process as well as actions that should be taken in the event of an emergency shall be provided to the public on an annual basis.
Information provided to the public shall include:
a)
Educational information on radiation b)
Contact points for additional information c)
Special needs of the handicapped d)
Initial actions following Early Warning System activation e)
Protective actions, such as sheltering or evacuation f)
Evacuation routes The company will coordinate its efforts with State and local authorities to ensure the public is informed by using the best means available. These means may include:
a)
Information in telephone books b)
Utility bill inserts Page 2 of 4
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NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 7.3.2, PAGE 7.12:
7.3.2 Radiological Monitoring The installed Radiation Monitoring System {RMS) consists of process monitors and area monitors which read out and record in the Control Room. The process system continuously monitors selected lines for radioactive effluents. The system's function is to warn personnel of increasing radiation levels, to give early warning of a system malfunction, and to record and control discharges of radioactive liquids and gases to the environment.
High range process monitors are installed to provide accurate indication of plant releases during and following an accident. The flow paths monitored include the ventilation vents, the process vent {part of the Gaseous Waste System), the main steam lines, and the turbine driven auxiliary feedwater pump exhaust. High range area monitors, located inside the containments, are installed to provide additional information on core integrity during and after a design basis accident.
In addition to the fixed radiation monitoring equipment, portable radiation monitoring equipment would be used to perform dose assessments.
The equipment consists of low and high range instruments to measure gamma, alpha, beta, and neutron radiation. This equipment is maintained by the Radiological Protection Department and is used on a routine basis. Portable gamma detection instrument are also dedicated for emergency kit use {See Appendix 10.5). The kits are set aside solely for emergency use and are inventoried and checked for calibration and operability on a quarterly basis.
Portable equipment is also available to take low or high volume air samples.
Battery operated air samplers can be used to collect low volume samples either onsite or offsite. Silver Zeolite cartridges would be used for sampling radioiodine with a minimum detectable activity capability of 5X10-8 microcuries per cc. Silver Zeolite has a low retention efficiency for Xenon and therefore, interference should Page 3 of 4
e NORTH ANNA POWER STATION EMERGENCY PLAN SECTION 8.7, PAGE 8.17:
8.7 attended by exercise controllers, observers, and key participants. Notes of critique comments shall be recorded. Observers shall complete critique sheets documenting their observations. Critique sheets shall be submitted in accordance with the schedule established for the exercise.
Within 60 days of the exercise, the Station Coordinator Emergency Planning shall submit to the Assistant Station Manager (Nuclear Safety and Licensing) a Post-Exercise Critique Report, which includes suggested corrective actions. Identified corrective actions will then be assigned for implementation.
8.6.6 Records of Emergency Exercises The Station Coordinator Emergency Planning shall ensure that the exercise scenario package and Post-Exercise Critique are filed in Station Records.
TESTING AND MAINTENANCE OF EMERGENCY EQUIPMENT Emergency equipment shall be periodically tested to identify and correct deficiencies. The specific scope and responsibilities for performing these tests are provided in administrative procedures. The testing shall include:
a)
The contents of the emergency kits dedicated for emergency use shall be inventoried quarterly and following each use.
b)
Dedicated emergency survey instrumentation shall be inventoried and operationally checked quarterly and following each use. Calibration of dedicated emergency survey instrumentation shall be performed in accordance with manufacturer's recommendations.
c)
Self-contained breathing apparatus shall be inspected and operationally checked monthly and following use during an emergency.
d)
State and local ringdown loop (lnsta-phone) extensions and the ringdown phone to the State EOC located at the station and LEOF shall be operationally checked on a monthly basis. In addition, NRC Emergency Notification System extensions and NRC Health Physics Network Page 4 of 4
e ATTACHMENT 3 JUSTIFICATION FOR PROPOSED REVISIONS TO THE SURRY AND NORTH ANNA POWER STATION EMERGENCY PLANS
e ATTACHMENT 3 Commitments specified within both the Surry and North Anna Power Station Emergency Plans (Sections 8.7.a and 8.7.b) regarding monthly performance of emergency kit inventories and emergency survey instrumentation inventories and operational checks are requested to be modified to require surveillance on a quarterly frequency, consistent with existing guidance.
Title 10 of the Code of Federal Regulations, Part 50.47(b), requires that emergency response plans for nuclear power reactors ensure adequate emergency facilities and equipment to support the emergency response are provided and maintained.
NUREG 0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, November 1980, Criterion H.10, states: "Each organization shall make provisions to
- inspect, inventory and operationally check emergency equipment/instruments at least once each calendar quarter and after each use."
Virginia Power's emergency kit surveillance program was established at Surry Power Station in 1978, before current regulatory guidance governing the frequency of performing such surveillance was issued.
Absent specific guidance, a monthly frequency for surveillance of radiation monitoring equipment was adopted at Surry consistent with Technical Specification Table 4.1-1, Minimum Frequencies for Check, Calibrations and Test of Instrument Channels, as it then existed. This approach was also adopted at North Anna. This frequency was incorporated into both the Surry and North Anna Power Station Emergency Plans when they were revised to address emergency planning regulations promulgated as a result of the March 1979 accident at Three Mile Island. In retrospect, the monthly frequency for emergency kit surveillances and survey instrumentation inventories is overly conservative.
Monthly emergency kit inspections are performed at North Anna Power Station in accordance with O-PT-114, Emergency Kit Inspection, and at Surry Power Station using O-HSP-EP-001, Emergency Plan Radiation Instruments and Emergency Kit Inspection.
Results of emergency kit inspections performed at each station over the previous two calendar years (1992 and 1993) were reviewed and verified satisfactory. Discussions with station personnel indicate that an average annual per-site savings of approximately 80 man-hours could be realized through modification of the surveillance frequency to conform with the NRC guidance of NUREG-0654. Over the remaining term of operation of both stations, this would result in savings in excess of the criteria for Cost Beneficial Licensing Action consideration. Furthermore, we consider that the proposed modification would continue to maintain an equivalent level of operational readiness.
It should be noted that emergency kits will continue to be inspected following drills, exercises and actual use. Consequently, inspections are expected to continue on more Page 1 of 2
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. than* a once per quarter frequency.
There are no items in the emergency kits which require monthly checks from a "shelf life" perspective.
Items identified as having "shelf lives" (e.g., Potassium Iodine tablets, batteries, respirator canisters, thermoluminescent dosimeters, self-reading dosimeters, portable instruments) have, at a minimum, a quarterly replacement frequency.
Approval of this Emergency Plan revision is requested since monthly emergency kit inventories and monthly emergency survey instrumentation inventories and operational checks are resource intensive but of marginal importance to safety. A quarterly frequency will allow personnel resources to be applied to resolution of issues having greater safety significance.
Finally, the intent of the regulations will continue to be met because the proposed quarterly frequency for surveillance is directly consistent with NUREG-0654/FEMA-REP-1 Criterion H.10.
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