ML23270B871

NRR E-mail Capture - Draft RAIs for License Amendment Request (LAR) to Revise the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Emergency Plan (L-2023-LLA-0083)

ML23270B871
Person / Time
Site:	Summer
Issue date:	09/27/2023
From:	Ed Miller NRC/NRR/DORL/LPL2-1
To:	Gao Y South Carolina Electric & Gas Co
References
L-2023-LLA-0083
Download: ML23270B871 (8)

Text

From: Ed Miller Sent: Wednesday, September 27, 2023 12:31 PM To: Yan.Gao@dominionenergy.com

Subject:

Draft RAIs for EP Changes LAR (L-2023-LLA-0083)

Attachments: Summer EOF Relocation and EP Staffing LAR Draft RAI R3.docx Mr. Gao, Attached is the NRC staffs draft RAI for the subject request. The questions are being transmitted to you to determine 1) If the questions clearly convey the NRC information needs, 2)

Whether the regulatory basis for the questions are clear, and 3) If the information has already been provided in existing docketed correspondence. Additionally, review of the draft question will allow you to determine what response time you can support. After youve had a chance to review, please let me know if you would like to have a clarification call or public meeting to discuss. Thank you.

Ed Miller (301) 415-2481

Hearing Identifier: NRR_DRMA Email Number: 2250 Mail Envelope Properties (SA1PR09MB74875C233398B7827EA8FAE4E9C2A)

Subject:

Draft RAIs for EP Changes LAR (L-2023-LLA-0083)

Sent Date: 9/27/2023 12:30:39 PM Received Date: 9/27/2023 12:30:00 PM From: Ed Miller Created By: Ed.Miller@nrc.gov Recipients:

"Yan.Gao@dominionenergy.com" <Yan.Gao@dominionenergy.com>

Tracking Status: None Post Office: SA1PR09MB7487.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 637 9/27/2023 12:30:00 PM Summer EOF Relocation and EP Staffing LAR Draft RAI R3.docx 55955 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

DRAFT REQUEST FOR ADDITIONAL INFORMATION (RAI)

LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLANS DOMINION ENERGY SOUTH CAROLINA V. C. SUMMER NUCLEAR STATION DOCKET NO. 50-395 By letter dated June 8, 2023 (Agencywide Documents Access and Management System Accession No. ML23159A233), Dominion Energy South Carolina (DESC) submitted a license amendment request (LAR) to revise the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Emergency Plan to the U.S. Nuclear Regulatory Commission (NRC) for prior review and approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR).

The following requests for additional information (RAI) is needed for the NRC staff to complete its review.

The following regulation is applicable to all RAIs:

Section 50.47 (b) establishes the planning standards that the onsite and offsite emergency response plans must meet for NRC staff to make a finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Planning Standard (2) addresses the capabilities of on-shift and augmented emergency response organization (ERO) staffing as follows:

On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

The NRC staff utilized the guidance in the following documents to conduct its review:

NUREG-0654/FEMA-REP-1, Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, December 2019 (ML19347D139).

Issue 1 In the amendment request, Section 2.4, Technical Summary, of Attachment 1, states:

The sections under 2.0 described the following:

In summary, this LAR concludes that VCSNS defense in depth capability is sufficient to support the extension of plant augmentation times.

Except for the development and deployment of beyond design basis capabilities, all the Section 2.0 discussions are based on changes and improvements that were in place when NUREG-0654, Revision 2, was issued. As such, the augmentation times provided by NUREG-0654, Revision 2, are based, in part, on the listed changes and improvements. Because the requirements of 10 CFR 50.155 are limited to beyond-design-basis external events and large area losses due to a fire or explosion, processes to meet 10 CFR 50.155 cannot be used to justify changes to site-specific emergency plans developed pursuant to 10 CFR 50.54(q). Specifically, the 10 CFR 50.155 requirements do not reduce or eliminate any of the responsibilities of the shift manager in response to radiological events.

Based on an NRC staff review of Section 2.0 of Attachment 1 of the LAR, does not provide sufficient justification for the proposed extension of augmented response times.

Request for Additional Information No. 1 Concerning Command and Control:

Issue 2 Section 3.4, Radiological Accident and Support of Operational Accident Assessments Function (Dose Assessments/Projections, Field Monitoring Teams, Radiation Protection), states:

The proposed change maintains responsibility for the on-shift dose assessment function as an ancillary duty of an RP [radiation protection] qualified individual.

The proposed change extends the 30-minute response time to 60-minutes for the augmented Dose Assessment Team Lead position and extends the remaining 60-minute response time for other dose assessment positions to 90-minutes. The Dose Assessment Team Lead serves in a support role for on-shift staff performing of dose assessment and providing oversight of RP qualified individuals responding at 60-minutes.

It is not apparent that RP qualified individuals are trained and qualified to the standards required by site-specific training program for RP technicians.

It does not appear that the dose assessment team lead is qualified to perform dose assessments.

Request for Additional Information No. 2 Concerning Radiation Protection:

Issue 3 Section 3.5, Plant System Engineering, Repair and Corrective Actions Functions, of , states:

The combination of indication-based Emergency Operating Procedures and application of Beyond Design Basis and FLEX strategies eliminate the need for Electrical or Mechanical Engineering resources prior to the proposed augmentation times. This conclusion has been validated via the detailed procedural analysis conducted to support this proposed change and is further supported by on-shift staffing analyses.

It was not apparent if there was a site-specific basis for having maintenance staff on-shift.

Request for Additional Information No. 3 Concerning Repair and Corrective Actions:

Issue 4 Section 3.5, Plant System Engineering, Repair and Corrective Actions Functions, of , states:

The combination of indication-based Emergency Operating Procedures and application of Beyond Design Basis and FLEX strategies eliminate the need for Electrical or Mechanical Engineering resources prior to the proposed augmentation times. This conclusion has been validated via the detailed procedural analysis conducted to support this proposed change and is further supported by on-shift staffing analyses.

As discussed in Issue 1, the FLEX strategy, as codified by 10 CFR 50.155, provides mitigation strategies for beyond design basis external events and for mitigation strategies for a loss of large areas of the plant impacted by the event, due to explosions or fire.

The LAR does not provide sufficient information to determine if the use of FLEX equipment provides a basis supporting the DESC determination that no immediate ECCS repair and corrective actions are likely necessary for on-shift personnel prior to augmentation of maintenance personnel for a spectrum of events.

Request for Additional Information No. 4 Concerning Repair and Corrective Actions:

Issue 5 Section 2.3.4.1, Performance Based Procedure Analysis, of Attachment 1, states:

A performance based analysis of applicable procedures and their bases was completed to provide the technical justification described in RIS 2016-10 [8.2].

The procedure analysis demonstrated on-shift personnel were able to perform required diagnostic activities for the first 90 minutes.

NUREG-0654, Revision 2, Table B-1, guidance provides one qualified electrician and one qualified mechanic responding within 60 minutes of an Alert or greater classification.

By their training and qualifications, maintenance technicians have addition capabilities that could support ECCS equipment repair and event mitigation.

Request for Additional Information No. 5 Concerning Repair and Corrective Actions: