ML23220A148
| ML23220A148 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/07/2023 |
| From: | James Holloway Virginia Electric & Power Co (VEPCO) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 23-188 | |
| Download: ML23220A148 (1) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 7, 2023 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 10 CFR 50.90 Serial No.:
23-188 NRA/GDM:
RO Docket Nos.: 50-280/281 License Nos.: DPR-32/37 PROPOSED EMERGENCY PLAN REVISION - RELOCATION OF THE TECHNICAL SUPPORT CENTER (TSC)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letters dated November 18, 2022 [Agencywide Document Access and Management System (ADAMS) Accession No. ML22322A182] and May 31, 2023 [ADAMS Accession No. ML23167B007], Virginia Electric and Power Company (Dominion Energy Virginia) submitted a license amendment request (LAR) to revise the Surry Power Station (SPS)
Units 1 and 2 Emergency Plan. The proposed change would relocate the Technical Support Center (TSC) from its current location adjacent to the Main Control Room (MCR) to the building located outside the Protected Area (PA) previously used as the site Local Emergency Operations Facility (LEOF). By email dated July 6, 2023, the NRC requested additional information to complete their review of the LAR. The Dominion Energy Virginia response to the NRC request for additional information is provided in Attachment 1.
Should you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.
Respectfu I ly, Jamr:I~
Vice President - Nuclear Engineering and Fleet Support COMMONWEAL TH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by James E. Holloway, who is Vice President - Nuclear Engineering and Fleet Support, 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 2!'!!._ day of Auju:,t, 2023.
My Commission Expires: 03 w.,,+ '3. I, Z.oZ.3.
Commitments contained in this letter: None.
Attachments:
- 1. Response to NRC Request for Additional Information
U.S. Nuclear Regulatory Commission - Region II Attn: Regional Administrator Marquis One Tower 245 Peachtree Center Avenue, NE., Suite 1200 Atlanta, Georgia 30303-1257 Mr. L. John Klos NRC Project Manager - Surry Power Station U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. G. Edward Miller NRC Senior Project Manager - North Anna Power Station U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector Surry Power Station State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street, Suite 730 Richmond, Virginia 23219 Serial No.: 23-188 Docket Nos.: 50-280/281 Page 2 of 2 Serial No.23-188 Docket Nos.: 50-280/281 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Virginia Electric and Power Company (Dominion Energy Virginia)
Surry Power Station Units 1 and 2
Serial No.23-188 Docket Nos.: 50-280/281 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELOCATED TECHNICAL SUPPORT CENTER LICENSE AMENDMENT REQUEST SURRY POWER STATION UNITS 1 AND 2 NRG COMMENT:
By application dated November 18, 2022 (Agencywide Documents Access and Management System Accession No. ML22322A182), Virginia Electric and Power Company (Dominion Energy Virginia) submitted a license amendment request to revise the Emergency Plan for Surry Power Station, Units 1 and 2, to the U.S. Nuclear Regulatory Commission (NRG) for review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically, the proposed change will relocate the Technical Support Center (TSC) from its current location adjacent to the Main Control Room (MGR) to the building outside the Protected Area previously used as the site Local Emergency Operations Facility (LEOF).
Requirement:
10 CFR 50.47(b)(B) requires adequate emergency facilities and equipment to support the emergency response are provided and maintained.
The staff utilized the guidance in the following documents to conduct its review:
NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980 (ADAMS Accession No. ML040420012), as amended in March 2002 (ADAMS Accession No. ML021050240). NUREG-0654, Section 11.H, Evaluation Criterion H.1 states that "Each licensee shall establish a Technical Support Center and onsite operations support center (assembly area) in accordance with NUREG-0696, Revision 1."
NUREG-0696, "Functional Criteria for Emergency Response Facilities," February 1981 (ML051390358)
The following requests for additional information (RAJ) are needed for the NRG staff to complete its review.
RA/1 NUREG-0696, Section 2.5 "Structure," states, in part, that "The TSC complex must be able to withstand the most adverse conditions reasonably expected during the design life of the plant including adequate capabilities for ( 1) earthquakes, (2) high winds ( other than tornadoes), and (3) floods. The TSC need not meet seismic Category I criteria or be qualified as an engineered safety feature (ESF). Normally, a well-engineered structure will provide adequate capability to withstand earthquakes." [emphasis added]
Page 1 of 6
Serial No.23-188 Docket Nos.: 50-280/281 Issue: In Subsection c. of Section 3.1.5, "Structure," of Attachment 1, "Description and Assessment of the Proposed Change, " the licensee states, in parl, that, This building was engineered and designed in accordance with the BOCA Code
[Reference 18] which was the uniform building code used by Virginia at the time the LEOF was designed.
It is not apparent how the Dominion Energy Virginia evaluation considers the proposed TSC building as a "we/I-engineered structure."
Request: Provide clarification that the proposed TSC is a "well-engineered structure" that will provide adequate capability to withstand earlhquakes.
Dominion Energy Virginia Response The proposed TSC will be located in the building that formerly housed the LEOF. The LEOF was constructed in accordance with the 1981 Building Officials Code Administration (BOCA) code, which was the applicable State of Virginia building code at the time of construction. Even though the LEOF was not designed as a Seismic Class I structure, any building constructed in accordance with the BOCA code is considered a well-engineered structure with adequate capability to withstand earthquakes.
RA/2 NUREG-0696, Section 2.5, "Structure," states, in parl, that the TSC complex must be able to withstand the most adverse conditions reasonably expected during the design life of the plant including adequate capabilities for (1) earlhquakes, (2) high winds ( other than tornadoes), and (3) floods. Winds and floods with a 1 DO-year-recurrence frequency are acceptable as a design basis.
Issue: In Subsection c. of Section 3.1.5, "Structure," of Attachment 1, the licensee states, in parl, that, The building has a finished floor elevation of 33 feet that is above the maximum UFSAR
[updated final safety analysis reporl] [Reference 19] flood level discussed above.
It is not apparent how the maximum flood level of 33 feet compares to a flood with a 100-year-recurrence frequency.
Request: Provide details on how the maximum flood level of 33 feet compares to a flood with a 1 DO-year-recurrence frequency.
Page 2 of 6
Dominion Energy Virginia Response Serial No.23-188 Docket Nos.: 50-280/281 The maximum 100-year flood in the vicinity of Surry Power Station (SPS) is 19 feet Mean Sea Level (MSL). The SPS Units 1 and 2 site grade is 26.5 feet MSL. The floor level elevation of the relocated Technical Support Center (TSC) is 33 feet MSL and is therefore above the site grade and meets the 100-year flood level criterion. The proposed TSC location is also outside FEMA's 100-year National Flood Hazard Layer (NFHL) Viewer map.
NUREG-0696, Section 2. 6, "Habitability," states, that protective equipment also shall be provided to allow TSC personnel to continue to function during the presence of low-level airborne radioactivity or radioactive surface contamination. Anticontamination clothing and respiratory protective gear are examples of equipment that shall be provided. This equipment shall be properly maintained to assure availability during an emergency.
Issue: In Section 3.1.6.c.4, "Protective Equipment," of Attachment 1, the licensee states, in part, that, By eliminating the need for TSC staff to travel to the MGR [main control room], crediting the design of the TSC ventilation system and the installed monitoring capability, in conjunction with the performance of local surveys and access control within the facilities, sufficient protection from and early indication of changing radiological conditions in the TSC is provided such that protective equipment can be dispatched to the TSC on an as needed basis rather than maintaining these items in the TSC.
It is not apparent to the staff how equipment dispatched to the TSC on an as needed basis rather than maintaining these items in the TSC meets the intent of the guidance in NUREG-0696 to assure availability during an emergency.
Request: Provide details on how protective equipment can be dispatched to the TSC on an as needed basis rather than maintaining these items in the TSC meets the intent of the guidance in NUREG-0696 to assure availability during an emergency.
Dominion Energy Virginia Response Dominion Energy Virginia proposes to modify the approach described in Section 3.1.6.c.4, "Protective Equipment," of Attachment 1 of the License Amendment Request (LAR) and provide an alternate means of addressing 10 CFR 50.47.b(B) and 10 CFR Part 50, Appendix E, Section IV.E.8.
10 CFR 50.47.b(B) establishes the requirement for adequate emergency facilities to provide emergency response. 10 CFR Part 50, Appendix E, Section IV.E.8, requires licensees to maintain an onsite technical support center (TSC) and emergency operations Page 3 of 6
Serial No.23-188 Docket Nos.: 50-280/281 facility (EOF) from which effective direction can be given and effective control can be exercised during an emergency. NUREG-0696 established criteria that can be used in evaluating whether licensees meet the regulatory requirements stated above and provides for the use of criteria different from that set forth in the NUREG provided the substitute criteria provide a basis for determining that the regulatory requirements have been met.
NUREG-0696, Section 2.6, Habitability, requires "protective clothing to be provided for personnel who must travel between the TSC and the Control Room or Emergency Operations Facility (EOF) under adverse conditions." It also requires that "protective clothing be provided so that TSC personnel may continue to function in the presence of low-level airborne radioactivity or radioactive surface contamination."
For the first condition under this section, NUREG-0696 describes a TSC that is located within a 2-minute walking distance of the Control Room to facilitate face-to-face communications for effective direction and control. With advances in communication technology and the use of improved plant computer displays, the distance between the Emergency Response Facilities is no longer material as interfacility travel is no longer necessary or performed. As a result, there is no longer a need to maintain protective clothing within the TSC for this purpose.
For the second condition under this section, NUREG-0696 describes adverse radiological conditions that could occur within the TSC assuming that other locations from which functions can be performed are not available. The facilities and equipment established under 10 CFR 50, Appendix E, IV.E.8.c and d, in June 2012, to provide additional capability for ensuring effective direction and control during an event have been enhanced, allowing TSC personnel to work from locations unaffected by changing radiological conditions onsite. These enhancements apply ALARA principals to ERO members and continue to meet regulatory requirements.
The TSC continues to be equipped with radiation monitors that would alert TSC personnel to the presence of low-level airborne radioactivity, and qualified radiation protection personnel assigned to the TSC would be available to validate radiation monitor alarms.
In the unlikely event that radiation levels rendered the TSC uninhabitable, the TSC functions would be transferred to the Control Room and Corporate Emergency Response Center (CERC), and TSC personnel would relocate to the near-site facility or alternative facility. Thus, the need for providing protective equipment in the TSC is obviated.
Should the need arise for TSC personnel to egress the site through a plume and/or contaminated environment, these personnel would report through a pre-established offsite monitoring point for contamination control purposes.
This process would be applicable without respect to the use of protective clothing by evacuating personnel. Site access in a contaminated environment has been performed periodically in evaluated exercises.
Page 4 of 6
RA/4 Serial No.23-188 Docket Nos.: 50-280/281 NUREG-0696, Section 2. 6, "Habitability," states, that sufficient potassium iodide shall be provided for use by TSC and control room personnel.
Issue: In Section 3.1.6.c.4, "Protective Equipment," of Attachment 1, the licensee states, in part, that, As provided in the current Emergency Plan, thyroid blocking agents will continue to be maintained onsite for use as needed.
It is not apparent that potassium iodide would be available for use in the proposed TSC.
Request: Provide clarification that potassium iodide would be readily available for use in the proposed TSC.
Dominion Energy Virginia Response In accordance with SPS emergency plan implementing procedures, potassium iodide is required to be maintained in the TSC and will continue to be required in the proposed TSC.
RA/5 NUREG-0696, Section 2.9, "Technical Data and Data System," states, in part, that the TSC displays shall include alphanumeric and/or graphical representations of:
Plant system variables, In-plant radiological variables, Meteorological information, and Offsite radiological information.
Issue: In Subsection c. of Section 3.1.9, Technical Data, Data Systems, and Data System Equipment SC Power Supplies," of Attachment 1, the licensee states, in part, that, Therefore, the TSC will continue to be provided with the required data inputs, data storage, data retrieval, and data trending capabilities to evaluate incident sequence, determine mitigating actions, evaluate damage, determine plant status during recovery operations, and perform the TSC function in accordance with NUREG-0696 [Reference 1] and NUREG-0737, Supplement 1 [Reference 2.
It is not clear apparent that proposed TSC will have the ability to display meteorological information and on-site and off-site radiological information.
Page 5 of 6
Serial No.23-188 Docket Nos.: 50-280/281 Request: Provide clarification that the proposed TSC will have the ability to display meteorological information and on-site and off-site radiological information.
Dominion Energy Virginia Response Currently, meteorological information and on-site radiation monitor data is displayed through the Plant Computer System (PCS). Meteorological data and effluent monitoring data is provided from the PCS System directly to the Meteorological Information and Dose Assessment System (MIDAS) for use in making offsite dose projections.
Offsite radiological data obtained from the field teams is relayed to the TSC by radio/telephone.
MIDAS and Field Team data is displayed in the TSC. The proposed TSC will maintain the same capability as the current TSC for display of the information below:
Plant system variables, In-plant radiological variables, Meteorological information, and Offsite radiological information.
RA/6 Issue: In Section 7.1.3, Technical Support Center," of Attachment 2, "Marked-Up SPS Emergency Plan Pages," the license states, in parl, that, Emergency response personnel will assemble at the primary TSC unless otherwise instructed by the SEM [Station Emergency Manager]. [emphasis added]
It is not apparent that proposed TSC will be the primary TSC as described in the proposed SPS Emergency Plan.
Request: Provide clarification that proposed TSC will be the primary TSC as described in the proposed SPS Emergency Plan.
Dominion Energy Virginia Response The reference to "primary" as part of the TSC description will be eliminated from the SPS Emergency Plan. The revised, marked-up SPS E-Plan page indicating this change is provided in Attachment 2.
Page 6 of 6 Serial No.23-188 Docket Nos.: 50-280/281 REVISED, MARKED-UP PAGE OF THE SPS E-PLAN Virginia Electric and Power Company (Dominion Energy Virginia)
Surry Power Station Units 1 and 2
1.0 Emergency Fac;nt;es ang Egujpmeot Serial No.23-188 Docket Nos.: 50-280/281 SEP Page 7.3 Revision +4-XX The facilities required in the implementation of the Emergency Plan consist of the Control Room (share<f for both Unit 1 and 2), the Operational Support Center (OSC), the Technical Support Center (TSC),
and the Corporate Emergency Response Center {CERC). These facilities were designed to meet the intent of the guidance in NUREG-0696 and the clarification in NUREG-0737 Supplement 1. In addition, a Joint Information Center (JIC) and a Local Media Center (LMC) are required for the implementation of the Emergency Plan. A description of each is given below.
1.1 Emergency Response Facjljt;es 1.1.1 contr.oJ B00ro The Control Room of the affected unit(s) shall be the initial location for command and control of the emergency response effort. Controls and instrumentation needed to diagnose plant conditions and to take immediate actions to place the affected unit(s) in a safe condition are available in the Control Room. Within the Control Room 1 the Station Emergency Manager has access to the infom1ation needed to classify the emergency. Redundant communications systems are also available in the Control Room to make the required onsite and offsite notifications. The Control Room has the required shielding and ventilation system to remain habitable during the emergency. Access to the Control Room shall be limited to these individuals responsible for carrying out assigned emergency response tasks plus other technical advisors, as necessary.
1.1.2 9ueu,t;000J support center The Operational Support Center (OSC}. located in the Work Control Center, is the designated reporting location for the pool of workers who compose Damage Control Teams, the Fire Brigade, the First Aid Team, and the Search and Rescue Team. Station Operations personnel not required for Control Room operation may also assemble at the OSC unless already perfom1ing an emergency function outside the Control Room (or otherwise instructed by the Shift Manager/SEM). In the event that the primary facility is unavailable; an Alternate OSC has been designated in the Maintenance Building.
1.1.3 Jechpical support center The TSC is located adjacentto the URit 1 CGRlml RoGm, aAd its anemate krnatioR is the Control
~
Training Building. Emergency response personnel will assemble at the primary TSC unless otherwise instructed by the SEM. The pi:ir~Uirij l;,catioRTSC contains controlled copies of selected manuals, procedures, drawings, and other documents as designated by Nuclear Records Department directives. lnfom,ation about pf ant conditions is available via real time data displays from the Plant Computer System (PCS). Refer to Section 7.3.4, Plant Process Parameter Monitoring, for a description of the PCS. Dedicated phone line communications have also been established with the Control Room to keep TSC personnel knowledgeable on current operating evolutions and to provide consultation and recommendations to the Control Room staff.
The construction of the facility walls and design of the ventilation system are such th3l the whole body and thyroid doses received by occup:mts of the TSC are below General Design Criteria limits.
Radiation monitoring equipment for making airborne particulate and direct radiation measurements is installed in the TSC. Reliable power is provided to the TSC from utility power and backed up by a UPS and a dedicated diesel genemtor wi h auto tran$fer capability. Tho TSC houses the PlaRt CeRlpYter Gyeten~ Qa,a Con~AH:tMiealioAe Preoeeeere. IFIJjY4e JFon1 fi)leRt eeReore ere preooeeed !By \\Aeeo 1miie BAB
Serial No.23-188 Docket Nos.: 50-280/281 SEP Page 7.4 Revision +4-XX
~o iRf8rmatioR is ~ransmitted te facilities includiRg Ute Cgntfol RoeRl and CERG for dis~la:y on itideo lenninelo. ReJor lo geotiert 7.3.4, Plan4 Proeeee Peren1O;0r Monitoring, fore doeeripUoA oftAB PGK 1.1.4 comornte Emergency Response Ctpter The CERC is the consolidated emergency operations facility (EOF) for Surry Power Station and North Anna Power Station. The CERC is located at the Innsbrook Technical Center in Glen Allen, Virginia.
The facility provides workstations for Corporate, Federal and State officials who may be assembled at this location. This facility is the designated central collection point for the receipt and analysis of all field monitoring data and the coordination of sample media. Plant data is available from the PCS. The Meteorological lnfom,ation and Dose Assessment System (MIDAS) is used to estimate offsrle doses.
1.1.s Joint iofQrmauon center ang Local Meg;a Geolec Official company statements to the media will be made from Joint Information Center (JIC) by the Chief Technical Spokesperson. The JIC is located at the Virginia State Police Administrative Headquarters in Chesterfield, Virginia. These company statements are prepared at the CERC.
A Local Media Center (LMC) may be activated as an adjunct to the JIC. The LMC for Surry Power Station is,located on Route 650 on company property. The facility is designated as the Surry Nuclear Information Center in normal operation. There are dedicated rooms for Dominion, NRC, FEMA, State. and media representatives as wefJ as an auditorium that will accommodate 200 people.
Provisions have been made to accommodate TV cameras, copying machines, typewriters, and other equipment needed for press conferences. Should the LMC become uninhabftable, sm3fl groups of the media, no more than 20, can be accommodated in fhe CERC with the approval of the Corporate Response Manager.
1.1.6 Alternate Facjljty Wbeo Under Ibreat 0c Exper;enc;ng Hosrne Act;on The Suny County Administration Building functions as a staging area for augmentation of emergency response staff if the site is under threat of or experiencing hostile action. This rocation has the capability to communicate with the CERC, control room, and plant security. The CERC has the capability to perform offsile notifications. The staff at the staging area working with CERC organization, provides capability for engineering assessment activities, including damage control team planning and preparation.
1.1.1 Near-s;te Location For Qffsjte Agency coorg;nat;oo The Surry Nuclear lnfom1ation Center is the location for the NRC and other offsite agency staff to interact face-to-face with emergency response personnel entering and leaving the nuclear power reactor site. This area provides a conference area with whiteboards, separate areas suitable for briefing and debriefing response personnel, telephones, site contact lists, computers with *internet access, access to a copier and office supplies, and access to plant data and radiological information. These provisions exist because the CERC is located more than 25 miles from the TSC.
1.2 communjcations systems The station communications system is designed to provide redundant means to communi.cate with all essential areas of the station associated with Surry Units 1 and 2 and to essential locations remote from the station during nom,al operation and under accident conditions. Communication systems vital to Units 1