ML15131A026

North Anna, Units 1 Ad 2, and ISFSIs - Proposed Emergency Action Level Revision, Correction of Equipment Mark Number

ML15131A026
Person / Time
Site:	North Anna
Issue date:	05/04/2015
From:	Clark G C Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
15-094
Download: ML15131A026 (20)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 4, 2015 U. S. Nuclear Regulatory Commission Serial No.: 15-094 Attention:

Document Control Desk NLOS/TJS:

RO Washington, DC 20555-0001 Docket Nos.: 50-338/339 72-16/56 License Nos.: NPF-4/7 SNM-2507 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS I AND 2 AND ISFSIs PROPOSED EMERGENCY ACTION LEVEL REVISION CORRECTION OF EQUIPMENT MARK NUMBER Pursuant to 10CFR50.90, Virginia Electric and Power Company (Dominion) is submitting a license amendment request to revise the Emergency Action Levels (EALs)for North Anna Power Station (NAPS).The proposed change is briefly summarized as follows: Change "GW-RI-178-1 Process Vent Normal Range" monitor to "VG-RI-180-1 Vent Stack B Normal Range" monitor for Initiating Condition (IC) RA2, EAL RA2.1. The incorrect equipment mark number was specified in our original NEI 99-01 EAL submittal on March 28, 2007.This change requires approval by the NRC prior to implementation because it introduces a deviation as defined in Regulatory Issue Summary 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels," Revision 4, dated January 2003, Supplement 2, dated December 12, 2005. Specifically, an EAL is altered such that classification of the event could be different from the site-specific EAL approved by the NRC and documented in an NRC Safety Evaluation Report (SER); in this case, the NRC's SER dated February 4, 2008.Attachment 1 provides a discussion of the proposed change. The marked-up and final proposed pages for the EAL are provided in Attachments 2 and 3, respectively.

Attachment 4 provides a comparison of the change using the differences and deviation guidance provided in NRC Regulatory Issue Summary 2003-18 Use of NEI 99-01,"Methodology for Development of Emergency Action Levels," Rev. 4, dated January 2003.We have evaluated the proposed amendment and have determined that it does not involve a significant hazards consideration as defined in 10CFR50.92.

The basis for this determination is included in Attachment

1. We have also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10CFR51.22(c)(9) and (10)(ii).

Pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change. The proposed EAL change has been reviewed and approved by~JAA5J Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Page 2 of 3 the Facility Safety Review Committee.

This change has been discussed with and agreed on by the Commonwealth of Virginia and local governmental authorities in the risk jurisdictions around NAPS.Dominion requests this review be performed on an expedited basis.Should you have any questions or require additional information, please contact Mr. Thomas Szymanski at (804) 273-3065.Sincerely, Gianna C. Clark Vice President

-Nuclear Support Services Commitments contained in this letter: None Attachments:

1. Discussion of Change 2. Marked-up EAL 3. Proposed Final EAL 4. EAL Comparison and Summary of Differences

/ Deviations COMMONWEALTH OF VIRGINIA ))COUNTY OF HENRICO )The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Ms. Gianna C. Clark, who is Vice President

-Nuclear Support Services, of Virginia Electric and Power Company. She has affirmed before me that she 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 her knowledge and belief.Acknowledged before me this day of M. 2015.My Commission Expires: 31, 2.1 Notary Public Commonwealth of Virginia Notary Public Reg. # 7520495 My Commission Expires January 31, 20 Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission

-Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 Dr. V. Sreenivas NRC Project Manager -NAPS U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Karen Cotton NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Attachment I DISCUSSION OF CHANGE NORTH ANNA POWER STATION -UNITS 1 & 2 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Attachment 1 Page 1 of 4 Background By letter dated March 28, 2007 (Serial No. 07-0001), as supplemented by letters dated October 2, 2007 (Serial No. 07-0001A) and January 18, 2008 (Serial No. 07-0001B), Virginia Electric and Power Company (Dominion) requested Nuclear Regulatory Commission (NRC) approval of changes to the emergency action levels (EALs) for North Anna Power Station Units 1 and 2 (NAPS) and Surry Power Station Units 1 and 2 (SPS).The requested changes were to convert from an EAL scheme based on NUREG-0654,"Criteria for Preparation and Evaluation of Radiological Emergency Response Plan and Preparedness in Support of Nuclear Power Plants," to one based on NEI 99-01,"Methodology for Development of Emergency Action Levels," Revision 4.NRC completed a technical and regulatory review of the proposed EAL changes and supporting documentation.

The NRC staff concluded that incorporation of the proposed EAL changes would not decrease the effectiveness of the applicable Emergency Plans and the revised Plans would continue to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E. The NRC Safety Evaluation Report (SER) dated February 4, 2008 documented the staffs rationale for accepting the proposed EALs for NAPS and SPS.Discussion During a recent emergency exercise, Dominion identified an administrative error in the current EAL RA2.1. An incorrect equipment mark number is listed as a potential release path that could result in an emergency classification different than what was approved in our SER. An Operations Department Standing Order associated with this EAL was issued as an operator aid to identify to station personnel the administrative error until this EAL is revised. Using the guidance contained in 10 CFR 50.54(q), we have determined that this change requires prior NRC review and approval to implement.

The proposed change follows: North Anna Item #1 Revise EAL RA2.1 to change "GW-RI-178-1 Process Vent Normal Range" monitor to"VG-RI-180-1 Vent Stack "B" Normal Range" monitor. The proposed change to the existing EAL is shown below in red: RA2.1 Alert [Mode Applicability:

All]

Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Attachment 1 Page 2 of 4 Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel resulting in a valid Hi-Hi alarm on any of the following radiation monitors: " RM-RMS-153 Fuel Pit Bridge" RM-RMS-152 New Fuel Storage Area" RM-RMS-162 (RM-RMS-262)

Manipulator Crane Area* RM-RMS-163 (RM-RMS-263)

Containment Area* RM-RMS- 159 (RM-RMS-259)

Containment Particulate

• RM-RMS-160 (RM-RMS-260)

Containment Gaseous* GW R! 178 1 Procs Vent No,"m,.al RanU <- VG-RI-180-1 Vent v Stack "B" Normal Range Conclusion Removing GW-RM-178-1 Process Vent Normal Range is a deviation to the monitoring scheme previously reviewed and approved by the NRC. This monitor was erroneously identified as being capable of monitoring damage to fuel outside of the Reactor Vessel.The correct monitor is VG-RI-180-1 Vent Stack "B" Normal Range. The deviation, using the guidance of RIS 2003-18, involves the removal of the previously NRC approved"incorrect" radiation monitor, as opposed to the addition of the correct radiation monitor.The technical basis for making this correction is that 1) the purpose of the Process Vent is to monitor system vents and tanks (Ref. UFSAR Section 9.3, Process Auxiliaries) and 2) one of the purposes of the Vent Stack "B" is to provide ventilation monitoring for the Fuel Building (Ref. UFSAR Section 9.4.5, Fuel Building).

Justification The proposed change affects the NAPS EALs, but does not alter the requirements of the Operating License or the Technical Specifications.

This change does not alter any of the assumptions used in the safety analyses, nor does it cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed change has no adverse effect on plant safety. Additionally, this change can be made without adverse impact to plant operations or to the health and safety of the public. Based on the technical analysis performed by Dominion, the proposed change is acceptable.

No Significant Hazards Consideration Dominion has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed change by addressing the three criteria set forth in 10 CFR 50.92(c) as discussed below.

Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Attachment 1 Page 3 of 4 Criterion 1: Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.This administrative change affects the NAPS EALs, but does not alter any of the requirements of the Operating License or the Technical Specifications.

The proposed change does not modify any plant equipment and does not impact any failure modes that could lead to an accident.

Additionally, the proposed change has no effect on the consequences of any analyzed accident since the change does not affect any equipment related to accident mitigation.

Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.

Criterion 2: Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No.The change affects the NAPS EALs by correcting an incorrect radiation monitor reference, but does not alter any of the requirements of the Operating License or the Technical Specifications.

It does not modify any plant equipment and there is no impact on the capability of the existing equipment to perform its intended functions.

No system setpoints are being modified.

No new failure modes are introduced by the proposed change. The proposed amendment does not introduce an accident initiator or any malfunctions that would cause a new or different kind of accident.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3: Does the proposed amendment involve a significant reduction in a margin of safety?Response:

No.The change affects the NAPS EALs, but does not alter any of the requirements of the Operating License or the Technical Specifications.

The proposed change does not affect any of the assumptions used in the accident analysis, nor does it affect any operability requirements for equipment important to plant safety. Therefore, the proposed change will not result in a significant reduction in the margin of safety.

Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Attachment 1 Page 4 of 4 In summary, Dominion concludes that the proposed change does not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).Environmental Consideration Dominion has determined that the proposed change would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements.

Dominion has evaluated the proposed change and has determined that the change does not involve: I. A Significant Hazards Consideration, II. A significant change in the types or significant increase in the amounts of an effluent that may be released offsite, or Ill. A significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.References

1. NRC SER dated February 4, 2008 (referenced Dominion Letter Serial No.07-001 dated March 28, 2007, as supplemented by letters dated October 2, 2007, and January 18, 2008), including the associated EAL Matrices (Hot & Cold).2. RIS 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels," Revision 4, dated January 2003, Supplement 2, dated December 21, 2005.3. RIS 2005-02, "Clarifying the Process for Making Emergency Plan Changes," dated February 14, 2005.

Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Attachment 2 MARKED-UP EAL Virginia Electric and Power Company (Dominion)

North Anna Station Units 1 and 2 and ISFSls

,DominIwn North Anna Power Station Title: Emergency Action Level Technical Bases Document Revision Number: Effective Date: x Revision Summary: Radiation Monitor (last bullet) revised for EAL RA2.1 from "GW-RI-178-1 Process Vent Normal Range" to "VG-RI-180-1 Vent Stack W Normal Range".Approvals on File North Anna Power Station Emergency Action Level Technical Bases Document Attachment 1 -Emergency Action Level Technical Bases Revision X RA2.1 Category: Sub-category:

Initiating Condition:

R -Abnormal Rad Release / Rad Effluent 2 -Onsite Rad Conditions Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel EAL: RA2.1 Alert Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel resulting in a valid Hi-Hi alarm on any of the following radiation monitors:* RM-RMS-153 Fuel Pit Bridge* RM-RMS-152 New Fuel Storage Area* RM-RMS-162 (RM-RMS-262)

Manipulator Crane Area* RM-RMS-1 63 (RM-RMS-263)

Containment Area" RM-RMS-1 59 (RM-RMS-259)

Containment Particulate" RM-RMS-1 60 (RM-RMS-260)

Containment Gaseous" GW R! 178 1 PrOcc.s Vent Normal RaRnge-* VG-RI-1 80-1 Vent Stack "B" Normal Range Mode Applicability:

All Basis: This EAL addresses specific events that have resulted, or may result, in unexpected increases in radiation dose rates within plant buildings and may be a precursor to a radioactivity release to the environment.

These events represent a loss of control over radioactive material and represent degradation in the level of safety of the plant. These events escalate from RU2.1 in that fuel activity has been released or is anticipated due to fuel heatup. This EAL applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage.Page 63 of 306 North Anna Power Station Revision X Emergency Action Level Technical Bases Document Attachment 1 -Emergency Action Level Technical Bases RA2.1 (cont)When considering escalation, information may come from:* Radiation monitor readings" Sampling and surveys" Dose projections/calculations" Reports from the scene regarding the extent of damage (e.g., refueling crew, radiation protection technicians)

This EAL is defined by the specific areas where irradiated fuel is located, such as the refueling cavity or Spent Fuel Pit (SFP).The bases for the SFP area radiation high-high alarms and containment area and ventilation radiation high alarms are a spent fuel handling accident and are, therefore, appropriate for this EAL. In the Fuel Building, a fuel assembly could be dropped in the fuel transfer canal or in the SFP. Should a fuel assembly be dropped in the fuel transfer canal or in the SFP and release radioactivity above a prescribed level, the area radiation monitors sound an alarm, alerting personnel to the problem. If valid high indication on RM-RMS-152 or RM-RMS-153 (new fuel area or spent fuel bridge crane area) is received while handling fuel in the Fuel Building, then placing in service the Auxiliary Building Iodine Filter Banks per 0-AP-30 is required (ref. 4). If Fuel Building area radiation reaches 1 R/hr, personnel are evacuated from the Fuel Building (ref. 1).Page 64 of 306 North Anna Power Station Revision X Emergency Action Level Technical Bases Document Attachment 1 -Emergency Action Level Technical Bases RA2.1 (cont)Elevated background at the monitor due to decreasing water level may mask elevated ventilation exhaust airborne activity and needs to be considered.

However, while radiation monitors may detect an increase in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered. For example, the monitor could in fact be properly responding to a known event involving transfer or relocation of a source stored in or near the SFP or responding to a planned evolution such as removal of the Reactor Vessel head. Interpretation of these EAL thresholds requires some understanding of the actual radiological conditions present in the vicinity of the monitors.This event escalates to a Site Area or General Emergency via radiological effluent EALs.NAPS Basis Reference(s):

1. O-AP-27 Malfunction of Spent Fuel Pit System 2. O-AP-5.2 MGP Radiation Monitoring System 3. O-AP-5.1 Common Unit Radiation Monitoring System 4. O-AP-30 Fuel Failure During Handling 5. 1-AP-5 (2-AP-5) Radiation Monitoring System 6. 1-AP-52 (2-AP-52)

Loss of Refueling Cavity Level During Refueling 7. NRC EAL FAQ 2006-013 Page 65 of 306 Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Attachment 3 PROPOSED FINAL EAL Virginia Electric and Power Company (Dominion)

North Anna Station Units I and 2 and ISFSls 0 Dominiow North Anna Power Station Title: Emergency Action Level Technical Bases Document Revision Number: IEffective Date: Revision Summary: Radiation Monitor (last bullet) revised for EAL RA2.1 from "GW-RI-178-1 Process Vent Normal Range" to "VG-RI-180-1 Vent Stack "B" Normal Range".ApprovalS on File North Anna Power Station Emergency Action Level Technical Bases Document Attachment 1 -Emergency Action Level Technical Bases Revision X RA2.1 Category: Sub-category:

Initiating Condition:

R -Abnormal Rad Release / Rad Effluent 2 -Onsite Rad Conditions Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel EAL: RA2.1 Alert Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel resulting in a valid Hi-Hi alarm on any of the following radiation monitors:* RM-RMS-153 Fuel Pit Bridge" RM-RMS-1 52 New Fuel Storage Area* RM-RMS-162 (RM-RMS-262)

Manipulator Crane Area* RM-RMS-163 (RM-RMS-263)

Containment Area" RM-RMS-159 (RM-RMS-259)

Containment Particulate

• RM-RMS-160 (RM-RMS-260)

Containment Gaseous* VG-RI-180-1 Vent Stack "B" Normal Range I Mode Applicability:

All Basis: This EAL addresses specific events that have resulted, or may result, in unexpected increases in radiation dose rates within plant buildings and may be a precursor to a radioactivity release to the environment.

These events represent a loss of control over radioactive material and represent degradation in the level of safety of the plant. These events escalate from RU2.1 in that fuel activity has been released or is anticipated due to fuel heatup. This EAL applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage.Page 63 of 306 North Anna Power Station Revision X Emergency Action Level Technical Bases Document Attachment 1 -Emergency Action Level Technical Bases RA2.1 (cont)When considering escalation, information may come from: " Radiation monitor readings" Sampling and surveys* Dose projections/calculations" Reports from the scene regarding the extent of damage (e.g., refueling crew, radiation protection technicians)

This EAL is defined by the specific areas where irradiated fuel is located, such as the refueling cavity or Spent Fuel Pit (SFP).The bases for the SFP area radiation high-high alarms and containment area and ventilation radiation high alarms are a spent fuel handling accident and are, therefore, appropriate for this EAL. In the Fuel Building, a fuel assembly could be dropped in the fuel transfer canal or in the SFP. Should a fuel assembly be dropped in the fuel transfer canal or in the SFP and release radioactivity above a prescribed level, the area radiation monitors sound an alarm, alerting personnel to the problem. If valid high indication on RM-RMS-152 or RM-RMS-153 (new fuel area or spent fuel bridge crane area) is received while handling fuel in the Fuel Building, then placing in service the Auxiliary Building Iodine Filter Banks per O-AP-30 is required (ref. 4). If Fuel Building area radiation reaches 1 R/hr, personnel are evacuated from the Fuel Building (ref. 1).Page 64 of 306 North Anna Power Station Revision X Emergency Action Level Technical Bases Document Attachment 1 -Emergency Action Level Technical Bases RA2.1 (cont)Elevated background at the monitor due to decreasing water level may mask elevated ventilation exhaust airborne activity and needs to be considered.

However, while radiation monitors may detect an increase in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered. For example, the monitor could in fact be properly responding to a known event involving transfer or relocation of a source stored in or near the SFP or responding to a planned evolution such as removal of the Reactor Vessel head. Interpretation of these EAL thresholds requires some understanding of the actual radiological conditions present in the vicinity of the monitors.This event escalates to a Site Area or General Emergency via radiological effluent EALs.NAPS Basis Reference(s):

1. O-AP-27 Malfunction of Spent Fuel Pit System 2. 0-AP-5.2 MGP Radiation Monitoring System 3. O-AP-5.1 Common Unit Radiation Monitoring System 4. O-AP-30 Fuel Failure During Handling 5. 1-AP-5 (2-AP-5) Radiation Monitoring System 6. 1-AP-52 (2-AP-52)

Loss of Refueling Cavity Level During Refueling 7. NRC EAL FAQ 2006-013 Page 65 of 306 Serial No.15-094 Docket Nos. 50-338/339, 72-16/56 Attachment 4 EAL Comparison and Summary of Differences I Deviations Virginia Electric and Power Company (Dominion)

North Anna Station Units 1 and 2 and ISFSIs RA2.1 EAL Comparison and Summary of Differences/Deviations a &EAL # [ Existing EAL Wording I Proposed EAL Wording I Difference/Deviation Justification RA2.1 RA2.1 Alert Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel resulting in a valid Hi-Hi Alarm on any of the following radiation monitors: " RM-RMS-153 Fuel Pit Bridge" RM-RMS-152 New Fuel Storage Area" RM-RMS-162 (RMS-RM-262)

Manipulator Crane Area" RM-RMS-163 (RMS-RM-263)

Containment Area" RM-RMS-159 (RMS-RM-259)

Containment Particulate" RM-RMS-160 (RMS-RM-260)

Containment Gaseous" GW-RM-178-1 Process Vent Normal Range RA2.1 Alert Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel resulting in a valid Hi-Hi Alarm on any of the following radiation monitors: " RM-RMS-153 Fuel Pit Bridge" RM-RMS-152 New Fuel Storage Area" RM-RMS-162 (RM-RMS-262)

Manipulator Crane Area" RM-RMS-163 (RM-RMS-263)

Containment Area" RM-RMS-159 (RM-RMS-259)

Containment Particulate" RM-RMS-160 (RM-RMS-260)

Containment Gaseous" VG-RI-180-1 Vent Stack "B" Normal Range Removing GW-RM-178-1 Process Vent Normal Range is a deviation to the monitoring scheme previously reviewed and approved by the NRC. This monitor was erroneously identified as being capable of monitoring damage to fuel outside of the Reactor Vessel. The correct monitor is VG-RI-180-1 Vent Stack "B" Normal Range. The deviation, using the guidance of RIS 2003-18, involves the removal of the previously NRC approved "incorrect" radiation monitor, as opposed to the addition of the correct radiation monitor.The technical basis for making this correction is that 1) the purpose of the process vent is to monitor system vents and tanks (Ref. Section 9.3, Process Auxiliaries) and 2) one of the purposes of the Vent Stack "B" is to provide ventilation monitoring for the Fuel Building (Ref. UFSAR Section 9.4.5, Fuel Building).