ML23346A097
| ML23346A097 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/11/2023 |
| From: | James Holloway Virginia Electric & Power Co (VEPCO) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 23-313 | |
| Download: ML23346A097 (1) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 11, 2023 10 CFR 50.90 U. S. Nuclear Regulatory Commission Serial No.: 23-313 Attention: Document Control Desk NRA/GDM: R2 Washington, DC 20555-0001 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLAN RELOCATION OF THE TECHNICAL SUPPORT CENTER RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION By letters dated January 13, 2023 [Agencywide Document Access and Management System (ADAMS) Accession No. ML23013A195] and June 27, 2023 [ADAMS Accession No. ML23192A215], 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. 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 November 13, 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 the attachment.
Should you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.
Respectfully, J~olloway Vice President - Nuclear Engineering and Fleet Support COMMONWEALTH 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-1.f!!!_ day of~eC<M bu--, 2023.
My Commission Expires: o'.j <f,S+ 31 1 Zt>D
Serial No.: 23-313 Docket Nos.: 50-338/339 Page 2 of 2 Commitments contained in this letter: None.
Attachment:
License Amendment Request - Relocation of the Technical Support Center, Response to NRC Request for Additional Information cc: 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. 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 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 NRC Senior Resident Inspector North Anna Power Station State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street, Suite 730 Richmond, Virginia 23219 Old Dominion Electric Cooperative R-North-Anna-Correspondence@odec.com
Serial No.22-313 Docket Nos.: 50-338/339 Attachment LICENSE AMENDMENT REQUEST- RELOCATION OF THE TECHNICAL SUPPORT CENTER RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Virginia Electric and Power Company (Dominion Energy Virginia)
North Anna Power Station Units 1 and 2
Serial No.23-313 Docket Nos.: 50-338/339 Attachment RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST- RELOCATION OF THE TECHNICAL SUPPORT CENTER NORTH ANNA POWER STATION UNITS 1 AND 2 NRG COMMENT:
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 (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 (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," February 1981 (ML051390358)
The following requests for additional information (RAJ) are needed for the NRG staff to complete its review.
RA/1 Requirement:
- 10 CFR 50.47(b)(8) requires adequate emergency facilities and equipment to support the emergency response are provided and maintained.
NUREG-0654, Section 11.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 Page 1 of 7
Serial No.23-313 Docket Nos.: 50-338/339 Attachment 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."
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. Earthquake loads were addressed in accordance with Section 916 of the 1981 BOCA Code. Consequently, the NAPS LEOF is considered a well-engineered structure with adequate capability to withstand earthquakes.
RA/2 Requirement:
- 10 CFR 50.47(b)(8) requires adequate emergency facilities and equipment to support the emergency response are provided and maintained.
NUREG-0654, Section 11.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 1DO-year-recurrence frequency are acceptable as a design basis.
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Serial No.23-313 Docket Nos.: 50-338/339 Attachment 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 1DO-year-recurrence frequency.
Request: Provide details on how the maximum flood level of 270 feet compares to a flood with a 1DO-year-recurrence frequency.
Dominion Energy Virginia Response The maximum 100-year flood in the vicinity of North Anna Power Station (NAPS) is 254.2 feet as shown on FEMA's 100-year National Flood Hazard Layer (NFHL) Viewer map.
Key data are as follows:
- The proposed TSC floor level is 270 feet.
- The NAPS Units 1 and 2 Updated Final Safety Analysis Report (UFSAR) identifies the maximum flood level for the North Anna site as 267.3 feet.
- The FEMA 100-year flood level is 254.2 feet.
Therefore, the TSC floor level is located above the maximum flood level for the NAPS site as well as the FEMA 100-year flood level.
RA/3 Requirement:
- 10 CFR 50.47(b)(B) requires adequate emergency facilities and equipment to support the emergency response are provided and maintained.
NUREG-0654, Section 11.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, Page 3 of 7
Serial No.23-313 Docket Nos.: 50-338/339 Attachment 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.
Dominion Energy Virginia Response In accordance with the revised NAPS emergency plan implementing procedures, potassium iodide tablets will be maintained in the proposed TSC.
RA/4 Requirement:
- 10 CFR 50.47(b)(B) requires adequate emergency facilities and equipment to support the emergency response are provided and maintained.
NUREG-0654, Section 11.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:
- Plant system variables,
- in-plant radiological variables,
- meteorological information, and
- offsite radiological information.
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.
Page 4 of 7
Serial No.23-313 Docket Nos.: 50-338/339 Attachment 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 directly to 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/5 Requirement:
- 10 CFR 50.47(b)(8) requires adequate emergency facilities and equipment to support the emergency response are provided and maintained.
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 RAls 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.
- i. Issue: LAR Section 3.1.8, "TSC Power Supplies," of Attachment 1, Paragraph Item c, states, in part, that the proposed TSC power distribution system consists of backup power from a dedicated 200kW/312. 5KVA diesel generator.
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Serial No.23-313 Docket Nos.: 50-338/339 Attachment However, during the staff's September 28, 2023, regulatory audit of the proposed TSC at NAPS, staff was not able to identify a backup power source, as listed in the LAR, that consist of a dedicated 200kW/312.5KVA diesel generator.
Request: Provide clarification of the proposed TSC's dedicated backup power design.
Dominion Energy Virginia Response An updated design review conducted after submittal of the LAR identified the need to upgrade certain areas of the initial design. The changes from the TSC design described in the LAR, as noted in the RAI, are described below.
An updated electrical design review of the relocated TSC electrical loading concluded that electrical needs would exceed the capacity of the 200kW/312.5KVA diesel generator that was originally specified in the LAR. Primarily due to HVAC upgrades, it was determined the 200kW/312.5KVA diesel generator needed to be upsized to a 250kW/312.5KVA diesel generator. However, due to the long lead time to procure the 250kW diesel generator, a 300kW/375KVA diesel generator, which exceeds the backup power requirement of 250kW, was procured and installed instead.
ii. Issue: LAR Section 3.1. 8, "TSC Power Supplies," of Attachment 1, states that the 50 KVA uninterruptable power supply (UPS) provides 15 minutes of power to critical TSC loads and that emergency lighting for the TSC Operations Floor and the NRG Communications Room are powered by the 50 KVA UPS.
However, during the staff's September 28, 2023, regulatory audit of the proposed TSC at NAPS, staff was not able to identify the proposed TSC emergency lighting that is powered by the 15-minute UPS.
Request: Provide clarification of the proposed TSC's emergency lighting design.
Dominion Energy Virginia Response The updated electrical design review concluded the proposed UPS was not compatible with the voltage requirements for the emergency lighting. Consequently, battery packs capable of meeting the same 15-minute criteria as described in the LAR for the UPS were installed in each emergency light as a suitable replacement for the UPS.
iii. Issue: LAR Section 3.1. 7, "Communications," of Attachment 1," states that the current revision of the Emergency Plan continues to maintain the location and the communications systems available to TSC personnel and that the proposed TSC will replicate the communications capabilities provided in the existing TSC.
However, during the staff's September 28, 2023, regulatory audit of the proposed TSC at NAPS, staff was not able to identify the TSC personnel access locations to Page 6 of 7
Serial No.23-313 Docket Nos.: 50-338/339 Attachment the Health Physics Network (HPN) communications system and if the proposed TSC HPN design conformed to the LAR.
Request: Provide clarification of the proposed TSC's HPN communication system design.
Dominion Energy Virginia Response The HPN phone line was inadvertently omitted from the initial design. The design has been modified to include an HPN line in the Dose Assessment Room of the relocated TSC.
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