ML23223A040

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Audit Plan License Amendment Request for Revision of the Emergency Plan to Support Relocation of the Technical Support Center
ML23223A040
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 08/25/2023
From: Geoffrey Miller
NRC/NRR/DORL/LPL2-1
To: Carr E
Dominion Energy Virginia, Virginia Electric & Power Co (VEPCO)
References
EPID L-2023-LLA-0006
Download: ML23223A040 (1)


Text

August 25, 2023 Mr. Eric S. Carr Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNITS 1 AND 2 - REGULATORY AUDIT RE: LICENSE AMENDMENT REQUEST FOR REVISION OF THE EMERGENCY PLAN TO SUPPORT RELOCATION OF THE TECHNICAL SUPPORT CENTER (EPID L-2023-LLA-0006)

Dear Mr. Carr:

By letter dated January 13, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23013A195), Virginia Electric and Power Company (Dominion Energy Virginia, the licensee) submitted a license amendment request (LAR) to revise the Emergency Plan for the North Anna Power Station (NAPS), Units 1 and 2. Specifically, the LAR proposed to relocate the Technical Support Center (TSC) from its current location adjacent to the Main Control Room (MCR) to the building outside the Protected Area (PA) used previously as the site Local Emergency Operations Facility (LEOF).

The U.S. Nuclear Regulatory Commission (NRC) staff has determined the need for a regulatory audit to be conducted in accordance with Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ML19226A274), for the NRC staff to examine the licensees non-docketed information with the intent to gain a better understanding of the LAR, to verify information, and to identify information that may require docketing to support the basis of the NRC staffs licensing decision.

The audit will be conducted September 28, 2023. The enclosed audit plan was discussed with Mr. Gary Miller of your staff. Any subsequent changes to logistical aspects of the audit will be coordinated with and communicated to your staff.

E. Carr If you have any questions, please contact me by telephone at (301) 415-2481 or by email at ed.miller@nrc.gov.

Sincerely,

/RA/

G. Edward Miller, Project Manager Plant Licensing Branch 2-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosure:

1. Audit Plan
2. Appendix A - North Anna Power Station TSC Walkthrough Checklist cc: Listserv

REGULATORY AUDIT PLAN FOR THE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLAN TO SUPPORT RELOCATING THE TECHNICAL SUPPORT CENTER AT THE NORTH ANNA POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-339

1.0 BACKGROUND

By letter dated January 13, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23013A195), Virginia Electric and Power Company (Dominion Energy Virginia, the licensee) submitted a license amendment request (LAR) to revise the Emergency Plan for the North Anna Power Station (NAPS), Units 1 and 2. Specifically, the LAR propose to relocate the Technical Support Center (TSC) from its current location adjacent to the Main Control Room (MCR) to the building outside the Protected Area (PA) used previously as the site Local Emergency Operations Facility (LEOF).

The U.S. Nuclear Regulatory Commission (NRC) staff has determined the need for a regulatory audit to be conducted in accordance with Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ML19226A274), for the NRC staff to examine the licensees non-docketed information with the intent to gain a better understanding of the LAR, to verify information, and to identify information that may require docketing to support the basis of the NRC staffs licensing decision.

2.0 REGULATORY AUDIT BASIS The NRC staff (i.e., audit team) will perform the audit to support its evaluation of whether the licensees request meets the of standards of section 50.47, Emergency plans, of Title 10 of the Code of Federal Regulations and the requirements of Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities.

3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The audit team will review the licensees proposed TSCs using the functional capabilities of NUREG-0696, Final Report, Functional Criteria for Emergency Response Facilities, February 1981 (ML051390358), and NUREG-0737, Supplement 1, Clarification of TMI [Three Mile Island] Action Plan Requirements, February 1989 (ML102560009), to determine if the licensee needs to submit any additional information contained in the analyses performed in support of the requested change to support or develop conclusions for the NRC staffs safety evaluation.

Enclosure 1

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT In the LAR, Attachment 1, Description and Assessment of the Proposed Change, the licensee stated that it proposes to relocate the TSC from its current location adjacent to the MCR to the building outside the PA used previously as the site LEOF. This change proposes alternative means of performing TSC functions than those identified in the NUREG-0696 and NUREG-0737, Supplement 1, guidance related to facility location.

The NRC staff requests the licensee to have the facilities readily available and accessible for the staffs review via a walkdown of the existing TSC and the proposed TSC, and representatives from operations, engineering, facilities, and emergency preparedness available during the visit should specific questions arise.

Based on its review of the proposed TSC, the NRC staff will determine whether it needs to request any additional information submitted on the docket for the staff to complete the review of the requested changes in the LAR.

5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff:

Michael Norris, Team Leader and Senior Emergency Preparedness Specialist Kenneth Mott, Emergency Preparedness Specialist Ed Miller, Project Manager 6.0 LOGISTICS The audit will be conducted on September 28, 2023, via a walkdown of the current TSC and the proposed new TSC. The staff requests a small conference room to accommodate the team for any needed discussions.

7.0 SPECIAL REQUESTS The audit team would like access to conduct a walkdown of the current TSC and the proposed new TSC. The NRC staff will use Appendix A, North Anna TSC Walkthrough Checklist, in its evaluation during the facilities walkthrough.

This walkthrough will focus on the proposed TSC information provided by Dominion Energy Virginia in its LAR as it relates to the applicable TSC guidance contained in NUREG-0696 and NUREG-0737. This walkthrough will provide the NRC staff with detailed information related to the NRC staffs evaluation of Dominion Energy Virginias proposed TSC relocation application.

8.0 DELIVERABLES An audit summary will be prepared within approximately 60 days of the completion of the audit.

If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the NRC staff will issue a separate request for additional information to the licensee.

Appendix A North Anna Power Station TSC Walkthrough Checklist Location The new location walking distance from the main control room. Note: The license amendment request (LAR) does not currently provide an estimate of walking time.

The new location also provides for improved off-hours staffing capability as responders would report directly to the Technical Support Center (TSC) without having to pass through security access controls for entry into the Protected Area (PA) as currently required.

The walking time from the Technical Services Building to the new TSC location is approximately five to six (5 to 6) minutes.

Size The new proposed TSC size is approximately 1,900 square feet, which assures a minimum of 75 square feet of working space per person for the 25 TSC Emergency Response Organization (ERO) positions.

TSC layout replicates the layout of the existing facility.

The TSC consist of a TSC Operations Floor and separate rooms for Operations Support, Technical Support, Dose Assessment, and NRC personnel.

The TSC contains a breakroom and bathroom facilities to support long-term operation of the facility.

Library space is provided in the TSC, with adequate space for the storage of plant records and historical data.

Adequate space to support maintenance of TSC data and communications systems and equipment and will include an equipment room for housing the TSC support systems/equipment to include Local Area Network (LAN) and communications network switches.

Structure The proposed TSC (former Local Emergency Operations Facilities [LEOF]) structure is made of 12-inch exterior masonry walls with horizontal joint reinforcement, and a 5-inch slab on grade.

The proposed TSC (former LEOF) as-designed building will withstand the 100-year wind speeds as described in the Updated Final Safety Analysis Report (UFSAR). The proposed location has a finished floor elevation of 270 feet, which is above the 267 ft MSL flood level specified in the UFSAR.

Habitability TSC ventilation system filter bank consists of a high-efficiency particulate air (HEPA) filter in series with a high efficiency gas adsorption (HEGA) filter with a nominal flow rate of 1000 cfm.

The TSC filter bank consists of a HEPA filter in series with a HEGA filter with a nominal flow rate of 1000 cubic feet per minute (cfm).

Enclosure 2

The TSCs HEGA filter temperature is monitored by a heat detector. If a flame is detected, the CO2 (carbon dioxide) suppression system floods CO2 into the duct mounted filter housing to extinguish the flame.

A radiation monitoring system (RMS) to provide continuous indication of the dose rate and airborne radioactivity in the TSC.

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.

Communications The communications capabilities available in the TSC include dedicated voice communications to the MCR, Operations Support Center (OSC), Corporate Emergency Response Center (CERC), Virginia Emergency Operations Center (VEOC), Primary Remote Assembly Area, Security Shift Supervisor and Radiation Protection Supervisor; Dominion Energy Emergency Notification System (DEENS); Station private branch exchange (PBX); General Office off premises exchange (OPX) lines; commercial lines; public address intercom; radio system; and NRC lines (Emergency Notification System (ENS), Health Physics Network (HPN), Reactor Safety Counterpart Link (RSCL),

Protective Measures Counterpart Link (PMCL), Management Counterpart Link (MCL),

LAN access).

TSC Power Supplies The new proposed TSC receives normal power from utility power, backup power from a dedicated 200kW/312.5KVA diesel generator, and a 50 KVA UPS with a 15-minute battery.

Technical Data, Data Systems, and Data System Equipment SC Power Supplies The proposed TSC will not contain the dedicated plant computer system (PCS) hardware but will continue to use PCS data in the same way as the existing TSC via workstations connected to the Station LAN via secure connections.

TSC LAN switches have two (2) fiber uplink ports connected to the Administrative Building Computer Room network which is powered from utility power and backed up by an uninterruptible power supply (UPS) and a dedicated diesel generator.

The proposed 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.

Records Availability and Management The proposed TSC contains a complete set of controlled drawings, technical manuals, and other records.

The proposed TSC contains controlled copies of selected manuals, procedures, drawings, and other documents as approved by the Facility Safety Review Committee be controlled copies.

ML23223A040 NRR-106 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NSIR/DPR/RLB/BC NAME GEMiller KGoldstein NDiFrancesco (KMott for)

DATE 8/11/2023 8/11/2023 8/15/2023 OFFICE NRR/DRO/IOLB/HFTL NRR/DORL/LPL2-1/BC NAME KMartin MMarkley (DKalathiveettil for)

DATE 8/11/2023 8/25/2023