ML083390740

Issuance of Amendments Regarding One-Time Completion Time Extension for Emergency Diesel Generator Fuel Oil Storage Tanks

ML083390740
Person / Time
Site:	North Anna
Issue date:	12/31/2008
From:	Stang J Plant Licensing Branch II
To:	Christian D Virginia Electric & Power Co (VEPCO)
Wright D, NRR/DORL, 301-415 -1864
References
TAC MD7533, TAC MD7534
Download: ML083390740 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 31, 2008 Mr. David A. Christian President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 SUB~IECT:

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING ONE-TIME COMPLETION TIME EXTENSION FOR EMERGENCY DIESEL GENERATOR FUEL OIL STORAGE TANKS (TAC NOS. MD7533 AND MD7534)

Dear Mr. Christian:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment Nos. 254 and 235 to Renewed Facility Operating License Nos. NPF-4 and NPF-7 for the North Anna Power Station, Unit Nos. 1 and 2. The amendments change the Technical Specifications (TSs) in response to your application dated December 17, 2007, as supplemented by letters dated July 22,2008, September 26,2008, and November 25,2008.

These amendments revise TS 3.8.3 to allow a one-time extended 14-day completion time (CT) for each of the two underground diesel fuel oil storage tanks (FOST) to permit removal of the current coating and to recoat the tanks in preparation for use of ultra-low sulfur diesel fuel oil. The change revises the TS to extend the CT associated with an inoperable emergency diesel generator FOST from 7 days to 14 days, applicable once for each of the two tanks.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

~g, Senior r ject Manager Plant Licensing Bran 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosures:

1. Amendment No. 254 to NPF-4

2. Amendment No. 235 to NPF-7

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 VIRGINIA ELECTRIC AND POWER COIVIPANY DOCKET NO. 50-338 NORTH ANNA POWER STATION, UNIT NO.1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 254 Renewed License No. NPF-4

1.

The Nuclear Regulatory Commission (the Comrnission) has found that:

A.

The application for amendment by Virginia Electric and Power Company et aI., (the licensee) dated December 17, 2007, as supplemented by letters dated July 22, 2008, September 26, 2008, and November 25, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comrnission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-4 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 254

,are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION li'V~ ("-Y Melanie C. Wong, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-4 and the Technical Specifications Date of Issuance: December 31, 2008

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-339 NORTH ANNA POWER STATION, UNIT NO.2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 235 Renewed License No. I\\IPF-7

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Virginia Electric and Power Company et aI., (the licensee) dated December 17, 2007, as supplemented by letters dated July 22, 2008, September 26, 2008, and November 25, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-7 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 235

, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION 7v(vUCtutu.(Va Melanie C. Wong, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-7 and the Technical Specifications Date of Issuance: December 31, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 254 RENEWED FACILITY OPERATING LICENSE NO. NPF-4 DOCKET NO. 50-338 AND TO LICENSE AMENDMENT NO. 235 RENEWED FACILITY OPERATING LICENSE NO. NPF-7 DOCKET NO. 50-339 Replace the following pages of the Licenses and the Appendix "A" Technical Specifications (TSs) with the enclosed pages as indicated. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

Remove Pages Insert Pages Licenses Licenses License No. NPF-4, page 3 License No. NPF-4, page 3 License No. NPF-7, page 3 License No. NPF-7, page 3 TSs TSs 3.8.3-1 3.8.3-1 3.8.3-2 3.8.3-2 3.8.3-3 3.8.3-3

-3 (2)

Pursuant to the Ad. Bnd 10 CFA Part 70, VEPCO to receive, possess, and use stellY lime specIaJ nuclear material as readorfuel, In accordance with the nmRaUons for 5tomge and amounts requIred lor reactor operation,,as described'" \\he Updated FU'U!I Safety Analylils Report; (3)

Pursuant to the Ad. and 10 CFR Par1s 30, 40, end 70, VEPCO to receive, possess, and U&e at any tJme any byproduct, 50lJr'G8, and GPecfaJ nuclear matenal ilS sealed neutron sources for reactor 61artUp, sealed sources for reactor InstrumenlaUon and radlaUon monltortng equlpmenl caDbratJon, and as fISsion deteetOl1i.'n am~ a& requlredj (4)

Pursuant 10 the Act and 10 CFR Parts 30, 40, end 70, VEPCO to receive, possess, and Ule In amounts as required any byproduct, SOUI'C8. or special nuclear material, without restridJoo 10 chemIcal or physical form, for lample analysis or Instrument calbf8\\1cn or associated wUh rudioElcUve upparetus or component; BIld (5)

PUniuant to the Act and 10 cFR Parts 30 and 70, VEPCO 'ao pDsseSS, but not r;eparate, IUCh byproduct and special nuclear materials is may be produced by the operallon of the fadDty.

O.

ThIs renewed operaUng Bcense shaIJ be deemed 10 contain and Is 6ubJeCi to the condlUons lipeetned In the following Commission regula:Uons In.

10 CFRChepter I: Part 20, SecOon 30.34 of Part 30, Sec:tJon 40.41 of Parl4D, SeetJo05 50.54 and 50..59 of Part 50, and SecUon 70.32 of PaJ170; Is 15ubJect to aD applicable provisions of the Act and 10 the Mes, regufatlons, end ctdeJSof the CommissIon now or hereafter In effeclj Bnd ls'subJect to tha eddillonal condlllonS

&p8c1!1ed or Incorporated below:

(1)

~8x1mum Power Levm VEPCO Is authorized to operate the No'rlh Anna PQwGr SlBlIon, Unit No.1, at reaatar CX)f*.powerlevels not In excess of 2B93 megawatts

, (thennsl).

(2)

!echnlca' Specifications The Technical Sp'sr.lflcaUons conlalned In AppendiX A, as revlsed*Uuough Amendment No. 254 '8J'8 hereby blcorporated In the renewed Ucense, llJ8 flcenseslhaR operate the 'acfiny In accordance with the Technical

. SpeclncallollS., '.:.

(

Renewed license No, NPF-4 Amendment No'. 254

-3 (3)

PunlUant lolhe Acl end 10 CFR Parts 30, 40, and 70, VEPCO 10 receive,.

possess. *and 1158 81 any Urns any byproduct, source, and 'pedal nuclear mEltlrfaJ as 18~fld neL!1lOn iOurces for reactor startup. sealed &OUTC81 for rBactor Instrumentallon and radlallon monBorfng equPmenl CBlJbratlon, and as flasslon detedors ~ Imoun18 u requll8di Pursuant to the Act and 10 eFR Parts 30. 40,.nd 70, VEPCO 10 receive, possess, and use In amounls as required.ny bWrocb:l, &aUIC8, or Ilpeclal nuclear malartal, without restric:tJon 10 chemlcaJ or ph)'llcsJ 'onn, for sample lI1a1)'als or 1n&tnlmenl celJraUon or 8SSoclated wIlh..

radloaclJve appUBws 0( camponenlll; and (5)

Punsuant 10 !he Act and 10 CFR Plrls 50, 40, IIIld 7D,VEPCO lD possess, but notlBpUBta, lueh byproduct end speclaf nuclear materials u may.be produced by the operalfon or the facility.

C:

Th!s renewed Dcensa &haD be deemed lD conlaln Bnd Is subject to the candiDo,.."

cpeclflad In ihe Comml&alon's regulaUons as sel fDfth In 1D CF.R Chapler IBnd Is subject to.11 appbble provtslons ollhe Ad. and to Ihe rutU, re;ulaDDI1II, and.

ortfeJ3 Q' the Commls5lon now or herea'ilu In effect; and b lub~ 10 !he additional condlUona specmed or IncolpOl1Iled belCJW:

(1)

Maximum ppwfr level VEPCO Is aulhol1zed to DpelBlB the laellll)' BtStBady stale fIIadGr CCIl'8 power IevBIs noIln exo8SS of 2893 megawatts (~ermaJ).

(2)

TeChQfcsr SpecllJcallpN Thll Technlclil Sp~dDl:8Vons contained In Appendix At U ~ Ihrough, I Nnendmlnt No. 235 are hereby ~orat.d In the renewud license.

ThelJeensel shlUJ opBnlllllhll 'sclDfy In accordanc:8 wIIh Ihs.Te.chnIcal.

6peclflcellDll8.

(3)

,Add'iuOnB! CopdlllpDI The msllerllp.cffled In rile foUClWfl:lu condfUons &haD be complele4 to the l7aU8fadIon 01 !he Comm!sslon wRhln the stated time periods.

roUoYring the Issuance or the condillon Dr' w11h1n.1h1 opBrdonal restrfcUons indicated. The removal of these c:ondlUons,hall be madll by an amendinent to the renewed license lupponed by I favoruble

.valuaUon by the Comm1sslon:

e.

If VEPCO plans to J'Bmove or'o males.'gnJRcant c:hangu In !he nonilld operiUon 01 equIpment lh81 conlrols the emounl of radloBetMty In effluents from !he North Anna Power StaUon, the

/

Renewed U~ No NPF-7 bendlQent N'o. 235

Di esel Fuel Oil and Starti ng Ai r 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil and Starting Air LCO 3.8.3 The stored diesel fuel oil and starting air subsystem shall be within limits for each required emergency diesel generator (EDG).

APPLICABILITY:

When associated EDG(s) is required to be OPERABLE.

ACTIONS

- - - - - - - - - - - - - - - - NOTE - - - -- - - - - - - - - - - -

Separate Condition entry is allowed for each EDG.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One fuel oil storage tank inoperable to perform an inspection or repairs.

A.I AND Verify replacement fuel oil is available.

Prior to removing tank from service A.2 Verify remalnlng fuel oil storage tank contains 2 45,000 gal.

Once per 12 *hours AND A.3 Verify above ground fuel oil tank contains 2 100, 000 gal.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND (continued)

North Anna Units 1 and 2 3.8.3-1 Amendment Nos. 254 and 235

Diesel Fuel Oil and Starting Air 3.8.3 ACTIONS

---

=-------------,----------------------r--------

COMPLETION TIME REQUIRED ACTION CONDITION A.4 Restore fuel oil

---

NOTE-----

storage tank to within A.

(continued)

The Completion limits.

Time for cleaning and recoating each fuel oil storage tank in preparation for use of ul tra low sulfur diesel fuel oil is 14 days. to be used once per tank 7 days

---

+---------------1---------

B.

One or more EDGs with B.1 Restore fuel oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel oil inventory inventory to within

< 90,000 gal and limits.

> 77,200 gal for reasons other than Condition A.

c.

One or more EDGs with C.1 Restore fuel oil total 7 days stored fuel oil total particulates within particulates not 1imit.

within limit.

---

t--------------------+-------

D.

One or more EDGs with 0.1 Restore stored fuel 30 days new fuel oil oil properties to properties not within within limits.

1imi t s.

E.

One or more EDGs with 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> the required starting E.1 Restore starting air receiver pressure to air receiver pressure

~ 175 psig.

< 175 psig and

~ 150 psig.

North Anna Units 1 and 2 3.8.3-2 Amendment Nos. 254 and 235

3.8.3 Diesel Fuel Oil and Starting Air ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time not met.

OR One or more EOGs diesel fuel oil or starting air subsystem not within limits for reasons other than Condition A, B, C, 0, or E.

F.1 Declare associated EDG(s) inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify fuel oil inventory ~ 90,000 gal.

31 days SR 3.8.3.2 Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Di esel Fuel Oil Testi ng Program.

In accordance with the Diesel Fuel Oil Testing Program SR 3.8.3.3 Verify each EDG

s ;

:: 175 psig. air start receiver pressure 31 days SR 3.8.3.4 Check for and remove each stored fuel oil accumulated water from storage tank.

92 days North Anna Units 1 and 2 3.8.3-3 Amendment Nos. 254 and 235

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 254 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-4 AND AMENDMENT NO. 235 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-338 AND 50-339

1.0 INTRODUCTION

By letter dated December 17, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML073520247), as supplemented by letters dated July 22,2008, September 26,2008, and November 25,2008 (ADAMS Accession Nos. ML082210012, ML082050360, and ML083310137, respectively), Virginia Electric and Power Company (the licensee, Dominion) submitted a request for changes to the North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2), Technical Specifications (TSs). The requested changes revised TS 3.8.3, to allow an one-time extended 14-day completion time (CT) for each of the two underground diesel fuel oil storage tanks (FOST) to permit removal of the current coating and to recoat the tanks in preparation for use of ultra-low sulfur diesel (ULSD) fuel oil. The supplements dated July 22, 2008, September 26, 2008, and November 25, 2008, provided clarifying information that did not change the scope of the original application and the initial proposed no significant hazards consideration determination.

The proposed changes would extend the CT associated with an inoperable EDG FOST from 7 days to 14 days applicable once for each of the two tanks.

2.0 REGULATORY EVALUATION

General Design Criterion (GDC) 2, "Design bases for protection against natural phenomena", of Appendix A, "General Design Criteria for Nuclear Power Plants," to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, requires that structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.

GDC 17, "Electric power systems," requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of structures, systems, and components

- 2 that are important to safety. The onsite system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure. The offsite power system is required to be supplied by two physically independent circuits that are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. In addition, this criterion requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of loss of power from the unit, the offsite, transmission network, or the onsite power supplies.

GDC 18, "Inspection and testing of electric power systems," requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing to assess the continuity of the systems and the conditions of their components.

Section 50.36 of 10 CFR, "Technical Specifications," requires a licensee's TSs to establish Limiting Conditions of Operation (LCO), and take appropriate actions when an LCO cannot be satisfied for equipment that is required for safe operation of the facility.

Section 50.63 of 10 CFR, "Loss of all alternating current power," requires a nuclear power plant to be able to withstand for a specified duration and recover from a complete loss of offsite and onsite alternate current (AC) sources.

Section 50.65 of 10 CFR, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," requires that preventive maintenance activities must not reduce the overall availability of the systems, structures, and components. It also requires that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.

Regulatory Guide (RG) 1.93, "Availability of Electric Power Sources," provides guidance with respect to operating restrictions if the number of available AC sources is less than that required by the TS LCO. In particular, this guide prescribes a maximum Allowed Outage Time (AOT) of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for an inoperable onsite or offsite AC source. It is noted that the compensatory actions, proposed by the licensee (References 1 and 10), will maintain operability of the onsite po'.".'er sources and the recommendations of this RG will not be invoked for this one-time extended AOT.

RG 1.137, "Fuel Oil Systems for Standby Diesel Generators" Regulatory Position 1, states that American National Standards Institute (ANSI) N195-1976, "Fuel Oil Systems for Standby Diesel-Generators," provides a method acceptable to the staff for complying with the pertinent requirements of GDC 17. Regulatory Position 1.c states that section 5.4 of ANSI N195-1976, "Calculation of Fuel Oil Storage Requirements," sets forth two methods for the calculation of fuel oil storage requirements. These two methods are (1) calculations based on the :.:lSsumption that the diesel generator operates continuously for 7 days at its rated capacity, and (2) calculations based on the time-dependent loads of the diesel generator. For the time-depandent load method, the minimum required capacity should include the capacity to power the engineered safety features.

RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," (Reference 5), describes a risk-informed approach, acceptable to the NRC, for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This RG

- 3 also provides risk acceptance guidelines for evaluating the results of such evaluations. While not directly applicable to temporary changes, the NRC staff used this RG for guidance in evaluating the licensee's proposed changes.

RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," (Reference 6), describes an acceptable risk-informed approach specifically for assessing proposed permanent TS changes in allowed outage times. This regulatory guide also provides risk acceptance guidelines for evaluating the results of such assessments. While not directly applicable to temporary changes, the NRC staff used this RG for guidance in evaluating the licensee's proposed changes.

NUREG-0800, Paragraph 1.1.H of Section 9.5.4 states that "a minimum of seven days supply of fuel oil for each diesel generator system is needed onsite to meet the engineered safety feature load requirements following a loss of offsite power and a design-basis accident (DBA)."

3.0 TECHNICAL EVALUATION

TS 3.8.3, "Diesel Fuel Oil and Starting Air," Condition A, is applicable when one FaST is inoperable for inspection or repair. A note will be added to the CT for Condition A to state: "The Completion Time for cleaning and recoating each fuel oil storage tank in preparation for use of ultra low sulfur diesel fuel oil is 14 days, to be used once per tank."

3.1 Risk-Informed Evaluation The evaluation presented below addresses the risk-informed decision making, that when the proposed changes result in a change in Core Damage Frequency (CDF) or risk, the increase should be small and consistent with the intent of the NRC's Safety Goal Policy Statement.

3.1.1 Tier 1: Probability Risk Assessment (PRA) Capability and Insights The first tier evaluates the impact of the proposed changes on plant operational risk. The Tier 1 review involves two aspects: (1) evaluation of the validity of the North Anna 1 and 2 PRA models and their application to the proposed change, and (2) evaluation of the PRA results and insights based on the licensee's proposed application.

PRA Quality The objective of the PRA quality review is to determine whether the licensee's PRA used in evaluating the proposed change is of sufficient scope, level of detail, and technical adequacy for this application. The NRC staff's review evaluated the PRA quality information provided by the licensee in their submittal, including industry peer review results.

The North Anna 1 and 2 PRA model, referred to as N105a, addresses internal events including internal flooding for at power conditions for both level 1 (core damage) and level 2 (containment performance and large early release). External events, including fires, seismic, and tornado events, are evaluated using a conservative conditional core damage probability assuming an unavailable FaST, as discussed separately below.

The PRA model is maintained and updated under the PRA configuration control program in

- 4 accordance with administrative procedures. Physical and procedural modifications, as well as changes in performance data, are reviewed for applicability, and the PRA is updated to reflect these changes on a regular schedule by qualified personnel, with independent reviews and approvals. The PRA model underwent a peer review in 2001 by the Westinghouse Owners' Group. Significant findings (level 'A' and 'B' findings and observations) have been resolved, or if not resolved were dispositioned with respect to this application. In response to the NRC's RAI, the licensee identified that there were no open 'A' level items, and provided a disposition of each of twelve open 'B' level items. The twelve 'B' level items were related to the PRA models for anticipated transient without scram (ATWS), internal flooding, interfacing systems loss-of-coolant accidents, conservatisms in the large early release frequency (LERF) analyses, and documentation issues. Since the unavailability of the FaSTs impact longer term loss-of-offsite power (LOOP) scenarios, the NRC staff agreed with the licensee's conclusion that the open items would not have any significant impact on the results of this application.

The licensee identified that as of the date of their submittal, there were no pending changes to the PRA model which would significantly impact the results supporting this application. The licensee committed to validate this conclusion prior to implementation of the proposed CT extension. The licensee identified a 5 x 10-12 truncation level used to generate the results used for the risk analyses which supports this application. This is more than five orders of magnitude below the baseline results, and the model results are judged by the licensee to be stable.

Based on review of the above information, the NRC staff finds, the licensee has satisfactorily applied the guidance contained in RG 1.177 (Sections 2.3.1, 2.3.2, and 2.3.3), RG 1.174 (Section 2.2.3 and 2.5), and Standard Review Plan (SRP) Section 19.1. The NRC staff also finds that the quality of the North Anna 1 and 2 internal events PRA is sufficient to support the risk evaluation for internal events provided by the licensee in support of the proposed license amendment.

For fire events, the main concern is those fires which can result in a LOOP which lasts more than several hours, such that during the extended CT such fires could result in a need for the EDGs and their fuel oil supply. If a fire does not cause a LOOP, or only a short duration loss, then the event is unaffected by the unavailability of the FaST.

The licensee evaluated its fire analyses from the North Anna Plant Individual Plant Examination of External Events (IPEEE), submitted to the NRC staff in June of 1994 (Reference 4), which identified four significant areas for fire risk. Only two areas were identified where a fire could result in a LOOP. For these areas, the total fire frequency was used as the fire initiator frequency, assuming that a LOOP occurs for any fire in the area. A failure of the remaining FaST could then result in a loss of all EDG fuel oil supply. The failure probability of a FaST was identified as 1.148E-5, based on generic data for tank failure rates.

The CDF due to fires in the cable vault and tunnel and the emergency switchgear room was calculated by the licensee as 1.86E-7/year. Since the FaST has no direct impact on containment*

bypass events (which contribute most significantly to LERF), no calculation of LERF due to fire events was made.

- 5 Seismic Events The licensee's IPEEE response used a focused-scope evaluation applying a seismic margins assessment, using a 0.3g review level earthquake. The frequency of this event is estimated by the licensee at 4.9E-5/year, based on values from NUREG-1488, "Revised Livermore Seismic Estimates for Sixty-Nine Nuclear Power Plant Sites East of the Rocky Mountains," April 1994. The earthquake is assumed to create a long-term LOOP, requiring the use of the FaST to maintain operation of the EDGs. If the remaining operable FaST fails (probability 1.148E-5, see above),

core damage is assumed to occur. Thus the seismic CDF is estimated by the licensee as 5.6E-10/year. No seismic LERF calculation was performed based on the same reasoning as discussed for fires.

Other External Events The licensee identified the potential for a high wind event (tornado) to cause an extended LOOP, such that if the operable FaST fails, core damage is assumed to occur. The tornado frequency was taken from the IPEEE as 1.9E-4/year, and with the FaST failure probability previously established at 1.148E-5, the CDF due to tornadoes is estimated by the licensee as 2.2E-9 per year.

Summary of External Events Risk Based on the analysis of external events discussed above, the NRC staff finds that the licensee has satisfactorily applied the guidance contained in RG 1.177 (Section 2.3.2 and Section 2.3.6),

RG 1.174 (Section 2.2.3), and SRP Section 19.2.

Shutdown and Transition Risk The proposed TS change is not applicable during shutdown conditions, and would be used to allow continued power operation of North Anna 1 and 2. Therefore, shutdown and transition risk issues are not relevant.

Uncertainty The licensee discussed areas of uncertainty applicable to this evaluation. The internal events model conservatively does not credit the use of the large above ground fuel oil supply, which although not seismically qualified, would be available to mitigate events not involving earthquakes or high winds. The internal events model also does not credit crosstie of the FaSTs, which permits any EDG to draw makeup fuel oil from either tank. While there is considerable uncertainty in the evaluation of external events, there is also substantial margin since the contribution of these events is not significant.

PRA Results and Insights The risk metrics for ~CDF and ~LERF were calculated by the licensee by assuming an additional 14 days of unavailability for each FaST (two 14-day outages). The Incremental Conditional Core Damage Probability (ICCDP) and Incremental Conditional Large Early Release Probability (ICLERP) for internal events were similarly calculated for each individual tank. The licensee's methodology is consistent with the guidance of RG 1.177, Section 2.3.4 and Section 2.4 and is acceptable to the NRC staff.

- 6 The baseline risk and configuration-specific risk with one of two FaSTs unavailable are presented in Table 1. Note that the licensee identified no significant difference in risk depending upon which specific FaST is unavailable. Also, the contribution from seismic and tornado risk is more than three orders of magnitude less than the other sources, thus, the other sources are not included.

The baseline risk of fires, seismic, and tornado risk is set to zero. The delta-risk calculations would subtract the baseline risk, and setting the baseline risk to zero yields a conservative estimate of the risk increase.

Table 1: CDF and LERF Summary CDF (yea(1)

LERF (yea(1)

Internal Fire Seismic/

Tornado Total Internal Fire Seismic/

Tornado Total Baseline 5.366E-6 0

0 5.366E-6 8.193E-7 0

0 8.193E-7 One FOST Unavailable 5.909E-6 1.86E-7 0

6.095E-6 8.306E-7 0

0 8.306E-7 Table 2: Application-Specific Results Core Damage Risk Large Early Release Risk Baseline Risk CDF ::: 5.37E-6/year LERF ::: 8.19E-7/year Risk with one FOST unavailable CDF ::: 6.1 OE-6/year LERF ::: 8.31 E-7/year Risk Increase per FOST outage ICCDP ::: 2.8E-8 (Guidance: < 5E-7 RG 1.177*)

ICLERP ::: 4.2E-1 0 (Guidance: < 5E-8 RG 1.177*)

Risk Increase - Total

~CDF ::: 5.6E-8/year (Guidance: <,/ E-6 per year - very small RG 1.174*)

~LERF ::: 8.4E-10/year (Guidance: < 1E-7 per year - very small RG 1.174*)

Applicable for permanent T5 changes only, but used to characterize the results for a temporary change.

The one-time change results in a temporary annual risk increase (in the year of implementation) for ~CDF and ~LERF which are considered "very small" per RG 1.174 criteria applicable to permanent TS changes. The risk impact of each individual entry into the TS measured by the ICCDP and ICLERP are less than the RG 1.177 guidance for permanent changes.

The I\\IRC staff finds that the licensee has satisfied the intent of RG 1.177 (Section 2.4), RG 1.174 (Sections 2.2.4 and 2.2.5), and SRP Section 19.2.

3.1.2 Tier 2 - Avoidance of Risk-Significant Plant Configurations The second tier requires a licensee to provide reasonable assurance that risk-significant plant equipment outage configurations will not occur when specific plant equipment is taken out-of-service in accordance with the proposed TS change.

The licensee identified Tier 2 restrictions applicable during implementation of each extended CT for planned maintenance activities by reviewing the component importance during the configuration of one FaST unavailable, and identifying appropriate restrictions where the existing

- 7 TSs do not prohibit the component unavailability. The results are restrictions primarily affecting plant electrical equipment and EDGs, and also charging pumps where both pumps for a single unit are unavailable. Unplanned emergent corrective maintenance would be addressed by the licensee's Tier 3 program.

The NRC staff finds the licensee's Tier 2 evaluation of potential risk-significant configurations and the proposed Tier 2 restrictions to support the implementation of changes to the TSs, acceptable.

3.1.3 Tier 3 - Risk-Informed Configuration Risk Management Program (CRMP)

The third tier requires a licensee to develop a program that ensures that the risk impact of out-of-service equipment is appropriately evaluated prior to performing any maintenance activity.

The licensee identified that its program for compliance with 10 CFR 50.65(a)(4) performs full PRA analyses of the planned maintenance configuration. Emergent configurations are identified and analyzed by the on-shift staff for prompt identification of risk-management actions. Configurations which approach or exceed industry guidance (NUMARC 93-01) risk limits are avoided, or addressed by compensatory measures. The licensee also stated that its program satisfies the requirements identified in RG 1.177, Section 2.3.

Based on the licensee's conformance to the requirements of the guidelines of RG 1.177, the NRC staff finds that the licensee's Tier 3 program supports the proposed changes to ~he TSs, and is acceptable.

3.1.4 Summary The Tier 1 risk impacts for the proposed one-time changes to the TSs to extend the CT for the EDG FaSTs are consistent with the RG 1.174 and RG 1.177 acceptance guidelines, which are applicable to permanent changes. The Tier 2 analysis and commitments provide reasonable assurance that risk-significant plant equipment outage configurations will not occur when specific plant equipment is taken out of service in accordance with the proposed TS change. The licensee's Tier 3 CRIVIP is consistent with the RG 1.177 CRMP guidelines. The proposed changes to the TSs satisfy the fourth key principle of risk-informed decision making that proposed changes should result in risk increases which are small and consistent with the NRC's Safety Goal Policy Statement, and are therefore acceptable for implementing risk-informed decision making.

3.2 Traditional Engineering Evaluation The scope of this evaluation is limited to the extension of the CT associated with each FaST. The removal of the existing tank coating and application of a coating compatible with ULSD fuel oil shall be evaluated by the licensee under their plant modification process.

The purpose of the proposed change to TS 3.8.3 is to extend the CT for each EDG FaST from 7 days to 14 days. This will allow the licensee a one-time extended 14-day CT fur each of the two underground diesel FaSTs to permit removal of the current coating and recoating of the tanks in preparation for use of ULSD fuel oil. The licensee stated that since the two FaSTs are the source of fuel oil for both units' EDGs, a dual-unit outage would be required to provide the necessary time to complete the required maintenance activities to remove, repair as necessary, and recoat the FaSTs. The licensee estimated that the required draining, inspecting, cleaning, and refilling of an underground FaST will take 7 to 10 days. The requested 14-day CT provides margin should

- 8 these activities take longer than expected to complete.

3.2.1 Compliance with Current Regulations The offsite and onsite power systems at North Anna 1 and 2 are designed to comply with the requirements of GDCs 17 and 18. As described in the licensee's UFSAR, Section 8.2.1, the offsite system or reserve ac power source is supplied from the switchyard, which is connected to both units via three reserve station service transformers. The three reserve station service transformers rated at 34.5/4.16 kilovolts (kV) can be connected to either the 500..kV or the 230-kV transmission network. On North Anna 1, a main generator breaker has been installed. This allows North Anna 1 to have its normal station service buses supplied from its normal station service transformers (backfed from the 500-kV switchyard) for most North Anna 1 trips. This arrangement reduces the probability of combined loading from both North Anna 1 and 2 normal and emergency buses on the reserve station service transformer.

For compliance with 10 CFR 50.63, an alternate ac (MC) diesel generator has been added to provide emergency power in the event of a Station Blackout (SBO). The MC system is auto-started by an SBO event. Operator action is required to align the MC diesel generator output to the desired emergency bus. The MC diesel generator has adequate capacity to start and supply the required safety-related equipment for the blacked-out unit.

North Anna 1 and 2 use four EDGs arranged such that each unit has two dedicated EDGs. Each EDG has 1OO-percent capacity to power the necessary safety-related equipment. The EDGs are situated in missile-protected rooms. The EDGs are rated at 2750 kilowatts (kW) for 8000 hours0.0926 days <br />2.222 hours <br />0.0132 weeks <br />0.00304 months <br /> per year (hr/yr), 3000 kW for 2000 hr/yr, and 3100 kW for 168 hr/yr.

Each EDG engine has an independent 1000-gallon storage day tank with a capacity for at least one hour of full-load operation when filled to the minimum allowed capacity. The day tanks are filled from two FaSTs, each with a 50,000-gallon capacity. The fuel lines and the underground FaSTs are of seismic Category 1 design and missile protected. Two FaSTs are required to ensure sufficient fuel oil supply for two EDGs (one at each unit) to operate at full load for 7 days.

The FaSTs can be replenished through existing connections by a fuel oil truck. The FaSTs can also be filled by gravity feed from an above ground main FaST which has a 5000-barrel (21 O,OOO-gallon) capacity. The above ground main FaST and associated piping are not designed to seismic Category 1 requirements and does not have missile protection. NUREG-0800, Paragraph 1.1.H of Section 9.5.4 and RG 1.137 recommend a minimum of 7 days supply of fuel oil for each EDG system to meet the engineered safety feature load requirements following a loss of offsite power and a design-basis accident. According to the North Anna 1 and 2 design bases, one seismic Category 1 FaST is the source of fuel oil for two EDGs at a time and both FaSTs are required for a 7-day supply of fuel oil for operation of one EDG at each unit. Based on a design of two FaSTs for four EDGs, one FaST does not have enough fuel oil capacity to support operation of two EDGs for 7 days as recommended in RG 1.137. North Anna 1 and 2 are not committed to RG 1.137. However, the intent of NUREG-0800 and RG 1.137 is satisfied by the combined fuel oil storage capacity available on site between the two FaSTs and the above ground main FaST.

3.2.2 Evaluation of Defense-in-Depth In order to maintain the defense-in-depth approach during the FaST inspection and coating

- 9 process, the licensee will align the four EDGs to the remaining FaST. This will maintain the functional capability of all four EDGs during the time that the one FaST is out of service. In a supplemental response dated November 25, 2008, (Reference 10), the licensee indicated that in the event of loss of offsite power and a DBA at one unit, four EDGs can operate from one FaST for 1.9 days without replenishment from the above ground tank. In its application (Reference 1),

the licensee stated:

More than 100,000 gallons of fuel oil will be available in the above ground main FaST If additional fuel oil is required over the amount stored in the tanks, 50,000 gallons will be available from an offsite supplier within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> During the planned outage of one FaST, two operable trains of safety equipment at each unit will continue to be capable of performing the necessary safety functions. Allowing for a single failure (other than a catastrophic failure of the available FaST) at each unit, at least one train of safe shutdown equipment will be available at each unit. This is consistent with accident analysis assumptions. The licensee will implement measures to minimize the likelihood of losing offsite power during the use of this one-time CT extension.

Prior to and during entry into TS 3.8.3, Condition A, the licensee will implement measures as detailed in the licensee's application (Reference 1) and as required by current TSs. These actions include:

1. Verify 50,000 gallons of replacement fuel oil is available offsite and transportation is available to deliver that volume of fuel oil within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

2. Ensure restrictions are placed on the remaining underground FaST (>45,000 gallons) and the 210,000 gallon above ground main FaST (~100,OOO gallons).

3. Verification of the fuel oil level in the redundant FaST is required to confirm the required minimum amount of diesel fuel oil. In addition, the above ground main FaST, used to supply make up to the underground FaSTs, is required to be verified to be at or above the minimum level. Verifications of onsite fuel oil are required on a 12-hour frequency to ensure an adequate source of fuel oil to the EDGs remains available.

4. Verify the operation of each fuel oil transfer pump and associated flow path per TS Surveillance Requirement 3.8.1.6 The above measures will assure that adequate fuel oil is available to support EDG mission times during the proposed CT extension.

In response to questions that were raised by the NRC staff, additional discussion and clarification of the contingencies being implemented was provided by the licensee (Reference 10). Some of the contingencies that the licensee identified include programmatic activities, such as protecting equipment necessary for maintaining offsite and onsite power systems. Furthermore, the licensee stated that electrical system distribution components and station equipment or combinations of equipment will not be scheduled for maintenance during each of the extended one-time CTs. The NRC staff finds that these measures will assure that the defenses against human errors will be adequately preserved during the proposed CT extension.

The licensee's supplemental response (Reference 10) has also confirmed that the flow path from the above ground main FaST to the underground FaSTs is verified approximately every 3 months when fuel is transferred to each underground FaST from the above ground FaST.

- 10 Based on this being a one-time change of limited duration, the NRC staff consicers the programmatic activities to be appropriate and necessary for maintaining defense-in-depth.

3.2.3 Evaluation of Safety Margins The existing design of North Anna 1 and 2 provides sufficient fuel oil for 7-day operation of two EDGs with two, seismic Category 1, FaSTs. During the inspection and recoating process, one FaST will not be available, thus reducing the total available capacity in seismic Category 1 FaSTs to approximately 45,000 gallons. According to the licensee's application, in the event that the above ground main FaST is not available, one underground FaST has enough capacity to support operation of one EDG at each unit for 4.5 days. This should provide adequate time for obtaining fuel from offsite sources.

The NRC staff evaluated the licensee's request to extend the CT for the EDG FaSTs to determine whether the SBO requirement in 10 CFR 50.63 would be degraded by the proposed changes and whether the overall availability of the EDGs would be reduced significantly as a result of maintenance activities associated with the FaSTs. In light of the recent experiences in offsite power system outages, it has been the NRC staff's position that the availability of an additional power source is a condition for approval of an extended EDG or associated system CT. As part of the licensee's coping strategy for an SBO event, an MC diesel generator has been added at the facility. This MC source will be available to manually restore power to the shutdown buses.

The licensee has proposed compensatory actions to reduce the risk of loss of redundant ac power required for safe shutdown during the implementation stages of the modifications. The licensee stated (References 1 and 10) that the following compensatory measures will be procedurally implemented to enhance plant safety during each 14-day outage period:

1. The condition of the offsite power supply and switchyard will be evaluated prior to entering the extended EDG FaST CT for elective maintenance.

2. Grid conditions will be evaluated prior to entering the extended EDG FaST CT for elective maintenance. The one-time extended CT will not be entered if stressed grid conditions are expected.

3. The one-time extended CT will not be entered if inclement weather conditions are forecasted Le., work under the extended CT will not be started if severe weather is forecasted to occur in the surrounding regions of the plant.

4. The system dispatcher will be contacted once per day to ensure no significant grid perturbations are expected during the extended EDG FaST CT.

5. The turbine-driven AFW pump will not be removed from service for planned maintenance activities during the extended EDG FaST CT.

6. Electrical system distribution components such as main, auxiliary or reserve station service transformers and switchyard equipment will not be scheduled for maintenance during each of the extended one-time CTs.

7. Operating crews will be briefed on the EDG FaST work plan and procedural actions regarding:

• LOOP and SBO

• 4 kV safeguards bus cross-tie [Unit 2 emergency bus cross-tie]

Reactor Coolant System bleed and feed

- 11

8. No elective maintenance will be scheduled for the plant direct current system.

9. An assessment of the overall impact of maintenance on plant risk will be made using a Configuration Risk Management Program before entering the TSs for planned EDG FOST maintenance activities.

Based on the plant design, the availability of the MC source, the ability to operate four EDGs in the event of a loss of offsite power, and the programmatic/compensatory measures to reduce the potential for a loss of offsite power event, the NRC staff considers that the safety margins are not significantly reduced for the one-time CT extension.

3.2.4 Summary The NRC staff evaluated the licensee's request to extend the CTs associated with EDG FOSTs for implementation of tank coating modifications from a deterministic perspective. The NRC staff's deterministic evaluation supports the proposed extension of the CT for the FOSTS from 7 days to 14 days on a one-time basis. The NRC staff's conclusion is based on the following: 1) the relatively small reduction in safety margin due to reduced fuel oil inventory, 2) the compensatory measures implemented to ensure availability of additional fuel oil and protection of other power sources, 3) the availability of the four EDGs capable of powering the selected loads necessary to achieve safe shutdown, and 4) the availability of an onsite MC source to cope with an SBO event.

Based on the above evaluation, the NRC staff finds the proposed changes to the North Anna 1 and 2 TSs provide reasonable assurance of the continued availability of the required electrical power to shut down the reactor and to maintain the reactor in a safe condition. Furthermore, the NRC staff concludes that the proposed TS changes are in accordance with 10 CFR 50.36, 10 CFR 50.63, 10 CFR 50.65, and meet the intent of GDCs 17 and 18. The proposed compensatory actions will satisfy the intent of RG 1.137 recommendations for onsite fuel oil storage capacity. Therefore, the NRC staff finds the proposed changes acceptable.

4.0 REGULATORY COMMITMENTS By letters dated July 22, 2008, September 26, 2008, and November 25, 2008, the licensee identified the following regulatory commitments made in support of this application:

1. Re-review the PRA model configuration control database prior to the implementation of the proposed completion time extension to reconfirm that the above evaluation remains valid.

2. Implement the Tier 2 restrictions identified in Table 5 of Attachment 2 (of the licensee's application) for planned maintenance activities during the proposed completion time extension.

3. Implement compensatory measures (as identified in Reference 10 and as described in the above safety evaluation) prior to entering the extended CTs for the EDG FOST recoating/repair of each tank.

The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are best provided by the licensee's administrative processes, including its commitment manageme.,t program. The above regulatory commitments do not warrant the creation of regulatory

- 12 requirements (items requiring prior NRC approval of subsequent changes). The NRC staff has reviewed the regulatory commitments and finds that the licensee's commitments provide adequate assurance that safe plant operation will not be affected by the extended CT.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Virginia State official was notified of the proposed issuance of the amendments. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (73 FR 2552). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

8.0 REFERENCES

1.

Letter from W. R. Matthews to U. S. Nuclear Regulatory Commission, "Proposed License Amendment Request One-Time Risk-Informed Extension to the Completion Time for EDG Fuel Oil Storage Tank Recoating," December 17,2007 (ADAMS Accession No. ML073520247).

2.

Letter from L. N. Hartz to U. S. Nuclear Regulatory Commission, "Proposed License Amendment Request One-Time Risk-Informed Extension to the Completion Time for EDG Fuel Oil Storage Tank Recoating," July 22,2008 (ADAMS Accession No. ML082050360).

3.

Letter from J. A. Price to U. S. Nuclear Regulatory Commission, "Implementation of Tier 2 Restrictions Proposed License Amendment Request One-Time Risk-Informed Extension to the Completion Time for EDG Fuel Oil Storage Tank Recoating," September 26,2008 (ADAMS Accession No. ML082700861).

4.

Virginia Electric and Power Company, "North Anna Power Station Units 1 and 2, Individual Plant Examination of Non-Seismic External Events and Fires," June 28, 1994 (ADAMS Accession No. ML080880090).

- 13

5.

USNRC, Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Revision 1,"

November 2002.

6.

USI\\IRC, Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," August 1998.

7.

NUREG-0800, Standard Review Plan 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance,"

June 2007.

8.

NUREG-0800, Standard Review Plan 19.1, "Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 3, June 2007.

9.

USNRC, NUREG-0800, Standard Review Plan 16.1, "Risk-Informed Decisionmaking:

Technical Specifications," Revision 1, March 2007.

10.

Letter from J. A. Price to U. S. Nuclear Regulatory Commission, "Proposed License Amendment Request One-Time Risk-Informed Extension to the Completion Time for EDG Fuel Oil Storage Tank Recoating," November 25,2008 (ADAMS Accession No. ML083310137).

Principal Contributors: Adel EI-Bassioni, NRR Andrew Howe, NRR Gurcharan Matharu, NRR Robert Wolfgang, NRR Date: December 31, 2008

December 31,2008 Mr. David A. Christian President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 SUB..IECT:

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING ONE-TIME COMPLETION TIME EXTENSION FOR EMERGENCY DIESEL GENERATOR FUEL OIL STORAGE TANKS (TAC I\\IOS. MD7533 AND MD7534)

Dear Mr. Christian:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment Nos.254 and 235 to Renewed Facility Operating License Nos. NPF-4 and NPF-7 for the North Anna Power Station, Unit Nos. 1 and 2. The amendments change the Technical Specifications (TSs) in response to your application dated December 17, 2007, as supplemented by letters dated July 22, 2008, September 26, 2008, and November 25, 2008.

These amendments revise TS 3.8.3 to allow a one-time extended 14-day completion time (CT) for each of the two underground diesel fuel oil storage tanks (FOST) to permit removal of the current coating and to recoat the tanks in preparation for use of ultra-low sulfur diesel fuel oil. The change revises the TS to extend the CT associated with an inoperable emergency diesel generator FOST from 7 days to 14 days, applicable once for each of the two tanks.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, IRA!

John Stang, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosures:

1. Amendment 1\\10. 254 to I\\JPF-4

2. Amendment No. 235 to NPF-7

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