ML23318A117
| ML23318A117 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/13/2023 |
| From: | Ed Miller Plant Licensing Branch II |
| To: | Geoffrey Miller Dominion Generation |
| References | |
| L-2023-LLA-0006) | |
| Download: ML23318A117 (7) | |
Text
From:
Ed Miller Sent:
Monday, November 13, 2023 1:01 PM To:
Gary D Miller
Subject:
Formal Issuance of RAIs for North Anna TSC LAR (L-2023-LLA-0006)
Attachments:
North Anna TSC Relocation LAR RAI.docx
- Gary, By letter dated January 13, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23013A195) Virginia Electric and Power Company (Dominion) submitted to the U.S. Nuclear Regulatory Commission (NRC), a proposed amendment to the license for the North Anna Power Station, Units 1 and 2 regarding a revision to the emergency plans to allow relocation of the Technical Support Center. By letter dated June 27, 2023 (ADAMS Accession No. ML23192A215), Dominion provided supplemental information regarding dose and meteorological data.
The NRC staff has reviewed the information submitted and needs additional information to complete its review and approval of the licensees submittal. These requests for additional (RAIs) are attached to this email and are released formally with a 30-day response period (December 13, 2023) requested.
Ed Miller (301) 415-2481
Hearing Identifier:
NRR_DRMA Email Number:
2309 Mail Envelope Properties (SA1PR09MB7487ABCB95D8DB8F275A2FE0E9B3A)
Subject:
Formal Issuance of RAIs for North Anna TSC LAR (L-2023-LLA-0006)
Sent Date:
11/13/2023 1:01:00 PM Received Date:
11/13/2023 1:00:00 PM From:
Ed Miller Created By:
Ed.Miller@nrc.gov Recipients:
"Gary D Miller" <gary.d.miller@dominionenergy.com>
Tracking Status: None Post Office:
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REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLAN VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION DOCKET NOS. 50-338 AND 50-339 By application dated January 13, 2023 (Agencywide Documents Access and Management System Accession No. ML23013A195), Virginia Electric and Power Company (Dominion Energy Virginia) submitted a license amendment request (LAR) to revise the North Anna Power Station (NAPS) Units 1 and 2 Emergency Plan to the U.S. Nuclear Regulatory Commission (NRC) 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 (MCR) to the building outside the Protected Area (PA) previously used as the site Local Emergency Operations Facility (LEOF).
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, dated November 1980 (ADAMS Accession No. ML040420012), as amended in March 2002 (ADAMS Accession No. ML021050240).
NUREG-0696, Functional Criteria for Emergency Response Facilities, dated February 1981 (ML051390358)
The following requests for additional information (RAI) is needed for the NRC staff to complete its review.
NUREG-0654,Section II.H, Evaluation Criterion H.1 states that a licensee shall establish a Technical Support Center and onsite operations support center (assembly area) in accordance with NUREG-0696, Revision 1.
NUREG-0696, Section 2.5 Structure, states that the TSC complex must be able to withstand the most adverse conditions reasonably expected during the design life of the plant including earthquakes, high winds (other than tornadoes), and floods. However, 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]
Issue: LAR Section 3.1.5, Structure, of Attachment 1, Description and Assessment of the Proposed Change, states, This building was engineered and designed in accordance with the BOCA code (Reference 23) which was the uniform building code used by Virginia at the time it was designed.
However, it is not clear to the staff that Dominion Energy Virginia considers the proposed TSC building as a well-engineered structure.
Request: Provide clarification that the proposed TSC is a well-engineered structure that will provide adequate capability to withstand earthquakes.
Requirement:
NUREG-0654,Section II.H, Evaluation Criterion H.1 states that a licensee shall establish a Technical Support Center and onsite operations support center (assembly area) in accordance with NUREG-0696, Revision 1.
NUREG-0696, Section 2.5 Structure, states that the TSC complex must be able to withstand the most adverse conditions reasonably expected during the design life of the plant including earthquakes, high winds (other than tornadoes), and floods.
It further states, winds and floods with a 100-year-recurrence frequency are acceptable as a design basis.
Issue: LAR Section 3.1.5, Structure, of Attachment 1, Description and Assessment of the Proposed Change, states, The proposed location has a finished floor elevation of 270 feet, which is above the maximum UFSAR [updated final safety analysis report] (Reference 22) flood level discussed above.
However, it is not clear to the staff how the maximum flood level of 270 feet compares to a flood with a 100-year-recurrence frequency.
Request: Provide details on how the maximum flood level of 270 feet compares to a flood with a 100-year-recurrence frequency Requirement:
NUREG-0654,Section II.H, Evaluation Criterion H.1 states that a licensee shall establish a Technical Support Center and onsite operations support center (assembly area) in accordance with NUREG-0696, Revision 1.
NUREG-0696, Section 2.6, Habitability, states, that sufficient potassium iodide shall be provided for use by TSC and control room personnel.
Issue: LAR Section 3.1.6.c, Protective Equipment, of Attachment 1, states, As provided in the current Emergency Plan, thyroid blocking agents will continue to be maintained onsite for use as needed.
However, it is not clear to the staff 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.
Requirement:
NUREG-0654,Section II.H, Evaluation Criterion H.1 states that a licensee shall establish a Technical Support Center and onsite operations support center (assembly area) in accordance with NUREG-0696, Revision 1.
NUREG-0696, Section 2.9, Technical Data and Data System, states that the TSC displays shall include alphanumeric and/or graphical representations of:
Issue: LAR Section 3.1.9, Technical Data, Data Systems, and Data System Equipment SC Power Supplies, of Attachment 1, states in part, 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 the requirements.
However, it is not clear to the staff that proposed TSC will have the ability to display meteorological information and on-site and off-site radiological information.
Request: Provide clarification that the proposed TSC will have the ability to display meteorological information and on-site and off-site radiological information.
Requirement:
NUREG-0654,Section II.H, Evaluation Criterion H.1 states that a licensee shall establish a Technical Support Center and onsite operations support center (assembly area) in accordance with NUREG-0696, Revision 1.
NUREG-0696, Section 2.8, Instrumentation, Data System Equipment, and Power Supplies, states, in part, that sufficient alternate or backup power sources shall be provided to maintain continuity of TSC functions and to immediately resume data acquisition, storage, and display of TSC data if loss of the primary TSC power sources occurs.
The following RAIs consist of proposed TSC design items that staff observed during the September 28, 2023, regulatory audit of the proposed TSC at NAPS, that staff request design clarification.