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 COMPANYRICHMOND, VIRGINIA 23261May 4, 2015U. S. Nuclear Regulatory Commission Serial No.: 15-094Attention:

Document Control Desk NLOS/TJS:

ROWashington, DC 20555-0001 Docket Nos.: 50-338/339 72-16/56License Nos.: NPF-4/7SNM-2507VIRGINIA ELECTRIC AND POWER COMPANYNORTH ANNA POWER STATION UNITS I AND 2 AND ISFSIsPROPOSED EMERGENCY ACTION LEVEL REVISIONCORRECTION OF EQUIPMENT MARK NUMBERPursuant to 10CFR50.90, Virginia Electric and Power Company (Dominion) issubmitting 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 ProcessVent Normal Range" monitor to "VG-RI-180-1 Vent Stack B Normal Range" monitor forInitiating Condition (IC) RA2, EAL RA2.1. The incorrect equipment mark number wasspecified in our original NEI 99-01 EAL submittal on March 28, 2007.This change requires approval by the NRC prior to implementation because itintroduces a deviation as defined in Regulatory Issue Summary 2003-18, "Use ofNuclear 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 bedifferent from the site-specific EAL approved by the NRC and documented in an NRCSafety 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 finalproposed 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 January2003.We have evaluated the proposed amendment and have determined that it does notinvolve a significant hazards consideration as defined in 10CFR50.92.

The basis forthis 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 ofeffluents that may be released offsite or any significant increase in individual orcumulative occupational radiation exposure.

Therefore, the proposed amendment iseligible for categorical exclusion from an environmental assessment as set forth in10CFR51.22(c)(9) and (10)(ii).

Pursuant to 10CFR51.22(b),

no environmental impactstatement or environmental assessment is needed in connection with the approval ofthe proposed change. The proposed EAL change has been reviewed and approved by~JAA5J Serial No. 15-094Docket Nos. 50-338/339, 72-16/56Page 2 of 3the Facility Safety Review Committee.

This change has been discussed with andagreed on by the Commonwealth of Virginia and local governmental authorities in therisk jurisdictions around NAPS.Dominion requests this review be performed on an expedited basis.Should you have any questions or require additional information, please contactMr. Thomas Szymanski at (804) 273-3065.

Sincerely, Gianna C. ClarkVice President

-Nuclear Support ServicesCommitments contained in this letter: NoneAttachments:

1. Discussion of Change2. Marked-up EAL3. Proposed Final EAL4. 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 andCommonwealth aforesaid, today by Ms. Gianna C. Clark, who is Vice President

-Nuclear Support Services, of Virginia Electric and Power Company.

She has affirmedbefore me that she is duly authorized to execute and file the foregoing document inbehalf of that company, and that the statements in the document are true to the best ofher knowledge and belief.Acknowledged before me this day of M. 2015.My Commission Expires: 31, 2.1 Notary PublicCommonwealth of Virginia Notary PublicReg. # 7520495My Commission Expires January 31, 20 Serial No. 15-094Docket Nos. 50-338/339, 72-16/56Page 3 of 3cc: U.S. Nuclear Regulatory Commission

-Region IIMarquis One Tower245 Peachtree Center Avenue, NESuite 1200Atlanta, GA 30303-1257 Dr. V. Sreenivas NRC Project Manager -NAPSU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Ms. Karen CottonNRC Project ManagerU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Serial No. 15-094Docket Nos. 50-338/339, 72-16/56Attachment IDISCUSSION OF CHANGENORTH ANNA POWER STATION -UNITS 1 & 2VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

Serial No. 15-094Docket Nos. 50-338/339, 72-16/56Attachment 1Page 1 of 4Background By letter dated March 28, 2007 (Serial No. 07-0001),

as supplemented by letters datedOctober 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) forNorth 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 andPreparedness 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 andsupporting documentation.

The NRC staff concluded that incorporation of the proposedEAL changes would not decrease the effectiveness of the applicable Emergency Plansand the revised Plans would continue to meet the standards of 10 CFR 50.47(b) and therequirements of Appendix E. The NRC Safety Evaluation Report (SER) datedFebruary 4, 2008 documented the staffs rationale for accepting the proposed EALs forNAPS and SPS.Discussion During a recent emergency

exercise, Dominion identified an administrative error in thecurrent 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 wasapproved in our SER. An Operations Department Standing Order associated with thisEAL 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),

wehave determined that this change requires prior NRC review and approval to implement.

The proposed change follows:North Anna Item #1Revise 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 theexisting EAL is shown below in red:RA2.1 Alert [Mode Applicability:

All]

Serial No. 15-094Docket Nos. 50-338/339, 72-16/56Attachment 1Page 2 of 4Damage 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 ofthe 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 VentvStack "B" Normal RangeConclusion 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, usingthe 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 Ventis to monitor system vents and tanks (Ref. UFSAR Section 9.3, Process Auxiliaries) and2) one of the purposes of the Vent Stack "B" is to provide ventilation monitoring for theFuel Building (Ref. UFSAR Section 9.4.5, Fuel Building).

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

This change does not alter anyof the assumptions used in the safety analyses, nor does it cause any safety systemparameters to exceed their acceptance limit. Therefore, the proposed change has noadverse effect on plant safety. Additionally, this change can be made without adverseimpact to plant operations or to the health and safety of the public. Based on thetechnical analysis performed by Dominion, the proposed change is acceptable.

No Significant Hazards Consideration Dominion has evaluated whether or not a significant hazards consideration (SHC) iswarranted with the proposed change by addressing the three criteria set forth in10 CFR 50.92(c) as discussed below.

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

Response:

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

The proposedchange does not modify any plant equipment and does not impact any failure modesthat could lead to an accident.

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

Based on this discussion, the proposedamendment does not increase the probability or consequences of an accidentpreviously evaluated.

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

Response:

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

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

No systemsetpoints are being modified.

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

Therefore, theproposed amendment does not create the possibility of a new or different kind ofaccident 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 theOperating License or the Technical Specifications.

The proposed change does notaffect any of the assumptions used in the accident

analysis, nor does it affect anyoperability requirements for equipment important to plant safety. Therefore, theproposed change will not result in a significant reduction in the margin of safety.

Serial No. 15-094Docket Nos. 50-338/339, 72-16/56Attachment 1Page 4 of 4In summary, Dominion concludes that the proposed change does not represent asignificant 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 definedby 10 CFR 20, nor would it change inspection or surveillance requirements.

Dominionhas evaluated the proposed change and has determined that the change does notinvolve:I. A Significant Hazards Consideration, II. A significant change in the types or significant increase in the amounts of aneffluent that may be released

offsite, orIll. 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 CFR51.22(b),

no environmental impact statement or environmental assessment need beprepared in connection with the proposed change.References

1. NRC SER dated February 4, 2008 (referenced Dominion Letter Serial No. 07-001dated March 28, 2007, as supplemented by letters dated October 2, 2007, andJanuary 18, 2008), including the associated EAL Matrices (Hot & Cold).2. RIS 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology forDevelopment 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,"

datedFebruary 14, 2005.

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

North Anna Station Units 1 and 2 and ISFSls

,DominIwn North Anna Power StationTitle: Emergency Action Level Technical Bases DocumentRevision Number: Effective Date:xRevision Summary:Radiation Monitor (last bullet) revised for EAL RA2.1 from "GW-RI-178-1 Process VentNormal Range" to "VG-RI-180-1 Vent Stack W Normal Range".Approvals on File North Anna Power StationEmergency Action Level Technical Bases DocumentAttachment 1 -Emergency Action Level Technical BasesRevision XRA2.1Category:

Sub-category:

Initiating Condition:

R -Abnormal Rad Release / Rad Effluent2 -Onsite Rad Conditions Damage to irradiated fuel or loss of water level that has or will result inthe uncovering of irradiated fuel outside the Reactor VesselEAL:RA2.1 AlertDamage to irradiated fuel or loss of water level that has or will result in the uncovering ofirradiated fuel outside the Reactor Vessel resulting in a valid Hi-Hi alarm on any of thefollowing 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 RangeMode Applicability:

AllBasis: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 releaseto the environment.

These events represent a loss of control over radioactive material andrepresent degradation in the level of safety of the plant. These events escalate from RU2.1 inthat fuel activity has been released or is anticipated due to fuel heatup. This EAL applies tospent fuel requiring water coverage and is not intended to address spent fuel which is licensedfor dry storage.Page 63 of 306 North Anna Power Station Revision XEmergency Action Level Technical Bases DocumentAttachment 1 -Emergency Action Level Technical BasesRA2.1 (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 thisEAL. In the Fuel Building, a fuel assembly could be dropped in the fuel transfer canal or in theSFP. Should a fuel assembly be dropped in the fuel transfer canal or in the SFP and releaseradioactivity above a prescribed level, the area radiation monitors sound an alarm, alertingpersonnel to the problem.

If valid high indication on RM-RMS-152 or RM-RMS-153 (new fuelarea or spent fuel bridge crane area) is received while handling fuel in the Fuel Building, thenplacing in service the Auxiliary Building Iodine Filter Banks per 0-AP-30 is required (ref. 4). IfFuel 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 XEmergency Action Level Technical Bases DocumentAttachment 1 -Emergency Action Level Technical BasesRA2.1 (cont)Elevated background at the monitor due to decreasing water level may mask elevatedventilation 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 areliable indication of whether or not the fuel is covered.

For example, the monitor could in factbe properly responding to a known event involving transfer or relocation of a source stored inor near the SFP or responding to a planned evolution such as removal of the Reactor Vesselhead. Interpretation of these EAL thresholds requires some understanding of the actualradiological 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 System2. O-AP-5.2 MGP Radiation Monitoring System3. O-AP-5.1 Common Unit Radiation Monitoring System4. O-AP-30 Fuel Failure During Handling5. 1-AP-5 (2-AP-5)

Radiation Monitoring System6. 1-AP-52 (2-AP-52)

Loss of Refueling Cavity Level During Refueling

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

North Anna Station Units I and 2 and ISFSls 0 Dominiow North Anna Power StationTitle: Emergency Action Level Technical Bases DocumentRevision Number: IEffective Date:Revision Summary:Radiation Monitor (last bullet) revised for EAL RA2.1 from "GW-RI-178-1 Process VentNormal Range" to "VG-RI-180-1 Vent Stack "B" Normal Range".ApprovalS on File North Anna Power StationEmergency Action Level Technical Bases DocumentAttachment 1 -Emergency Action Level Technical BasesRevision XRA2.1Category:

Sub-category:

Initiating Condition:

R -Abnormal Rad Release / Rad Effluent2 -Onsite Rad Conditions Damage to irradiated fuel or loss of water level that has or will result inthe uncovering of irradiated fuel outside the Reactor VesselEAL:RA2.1 AlertDamage to irradiated fuel or loss of water level that has or will result in the uncovering ofirradiated fuel outside the Reactor Vessel resulting in a valid Hi-Hi alarm on any of thefollowing 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 IMode Applicability:

AllBasis: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 releaseto the environment.

These events represent a loss of control over radioactive material andrepresent degradation in the level of safety of the plant. These events escalate from RU2.1 inthat fuel activity has been released or is anticipated due to fuel heatup. This EAL applies tospent fuel requiring water coverage and is not intended to address spent fuel which is licensedfor dry storage.Page 63 of 306 North Anna Power Station Revision XEmergency Action Level Technical Bases DocumentAttachment 1 -Emergency Action Level Technical BasesRA2.1 (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 thisEAL. In the Fuel Building, a fuel assembly could be dropped in the fuel transfer canal or in theSFP. Should a fuel assembly be dropped in the fuel transfer canal or in the SFP and releaseradioactivity above a prescribed level, the area radiation monitors sound an alarm, alertingpersonnel to the problem.

If valid high indication on RM-RMS-152 or RM-RMS-153 (new fuelarea or spent fuel bridge crane area) is received while handling fuel in the Fuel Building, thenplacing in service the Auxiliary Building Iodine Filter Banks per O-AP-30 is required (ref. 4). IfFuel 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 XEmergency Action Level Technical Bases DocumentAttachment 1 -Emergency Action Level Technical BasesRA2.1 (cont)Elevated background at the monitor due to decreasing water level may mask elevatedventilation 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 areliable indication of whether or not the fuel is covered.

For example, the monitor could in factbe properly responding to a known event involving transfer or relocation of a source stored inor near the SFP or responding to a planned evolution such as removal of the Reactor Vesselhead. Interpretation of these EAL thresholds requires some understanding of the actualradiological 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 System2. 0-AP-5.2 MGP Radiation Monitoring System3. O-AP-5.1 Common Unit Radiation Monitoring System4. O-AP-30 Fuel Failure During Handling5. 1-AP-5 (2-AP-5)

Radiation Monitoring System6. 1-AP-52 (2-AP-52)

Loss of Refueling Cavity Level During Refueling

7. NRC EAL FAQ 2006-013Page 65 of 306 Serial No. 15-094Docket Nos. 50-338/339, 72-16/56Attachment 4EAL 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 RA2.1RA2.1 AlertDamage to irradiated fuel or loss of water level thathas or will result in the uncovering of irradiated fueloutside the Reactor Vessel resulting in a valid Hi-HiAlarm 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 CraneArea" 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 RangeRA2.1 AlertDamage to irradiated fuel or loss of water level thathas or will result in the uncovering of irradiated fueloutside the Reactor Vessel resulting in a valid Hi-HiAlarm 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 CraneArea" 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 RangeRemoving GW-RM-178-1 Process VentNormal Range is a deviation to themonitoring scheme previously reviewedand approved by the NRC. This monitorwas erroneously identified as beingcapable of monitoring damage to fueloutside of the Reactor Vessel. Thecorrect monitor is VG-RI-180-1 VentStack "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 ofthe correct radiation monitor.The technical basis for making thiscorrection is that 1) the purpose of theprocess vent is to monitor system ventsand tanks (Ref. Section 9.3, ProcessAuxiliaries) and 2) one of the purposesof the Vent Stack "B" is to provideventilation monitoring for the FuelBuilding (Ref. UFSAR Section 9.4.5, FuelBuilding).