ML18153D140
| ML18153D140 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/30/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-619, NUDOCS 9210080171 | |
| Download: ML18153D140 (12) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 30, 1992 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 AND 2 10 CFR 50 APPENDIX E EXEMPTION REQUEST Serial No.
NO/RBP Docket Nos.
License Nos.92-619 R6 50-280 50-281
- DPR-32 DPR-37 Pursuant to 1 O CFR Part 50.12, Virginia Electric and Power Company requests a one-time exemption from the requirement to conduct the i 992 Surry Power Station Emergency Plan exercise pursuant to 1 O CFR Part 50, Appendix E,Section IV.F.2.
Specifically, we request a one-time exemption from the provision requiring each site to annually exercise its emergency plan as defined as the integrated exercise scheduled for NRC evaluation. This NRC evaluated emergency plan exercise for Surry Power Station is presently scheduled for November 18, 1992.
The request to not conduct the scheduled annual exercise with NRC evaluation is based on our established level of performance regarding emergency preparedness and demonstration that our Emergency Plan is adequate and capable of being implemented.
The request is further supported by our sustained high level of performance, including satisfactory completion of 1992 drills which have already exercised and met the intent of the requirement. We conclude that the adequacy of our emergency preparedness program has already been determined to be sufficient.
An additional annual exercise at Surry to demonstrate that adequate protective measures can and will be taken in the event of a radiological emergency is not necessary to provide reasonable assurance that the health and safety of the public will be maintained.
Justification for this request is further supported by provisions, established in 44 CFR Part 350.9, which provide that the testing of emergency response capabilities on a biennial frequency is sufficient to demonstrate the reasonable assurance finding.
Approval of this exemption is requested to reduce the duplication of demonstration of emergency response elements which are otherwise routinely performed as part of rd:nr-:,, n, 9210080171 920930 PDR ADOCK 05000280 F
PDR *
- station Emergency Plan exercise in 1993, subject to NRC rulemaking activities. We believe that this approach has generic merit and are considering submitting a request for rulemaking as a separate activity.
Very truly yours, f',
1 ()/~)~'
v\\Y \\.. "\\ \\S W. L. S(ew~vw Senior Vice President - Nuclear Attachment 1.
Appendix E Exemption Request
- 2.
Virginia Power Nuclear Emergency Preparedness 1992 Drill and Exercise Schedule
- 3.
References cc:
Dr. Thomas Murley Office of Nuclear Reactor Regulations U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Stewart D. Ebneter Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. W. H. Rankin Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station Mr. George O'N. Urquhart Department of Emergency Services 31 O Turner Road Richmond, Virginia 23225 Mr. Joe Colvin Nuclear Management and Resources Council 1776 Eye Street, N. W.
Suite 300 Washington, D. C. 20006-2496
ATTACHMENT 1 SURRY POWER STATION UNIT 1 AND 2 1 OCFRSO APPENDIX E EXEMPTION REQUEST ANNUAL EMERGENCY EXERCISE EXEMPTION REQUEST
SUMMARY
Pursuant to 1 O CFR 50.12, we request a one-time exemption from the requirement to conduct the 1992 Surry Power Station Emergency Plan annual exercise pursuant to 10 CFR Part 50, Appendix E, Section IV.F.2. The requirement states that "Each licensee at each site shall annually exercise its emergency plan." We are requesting an exemption from the requirement to conduct an integrated exercise specifically scheduled for NRC evaluation. We believe that this exemption request is justified because the Company emergency plans, which have been exercised in 1992 during numerous drills, were determined to be exercised satisfactorily, and therefore, the intent of the regulation has already been met.
BACKGROUND Emergency planning regulations, promulgated as a result of the March, 1979 accident at Three Mile Island, govern virtually all aspects of a licensee's emergency preparedness program and have done much to lay the basis for a structured formal response capability.
These requirements cover a broad spectrum, including emergency organizational structure, emergency equipment and response facilities, and emergency assessment mechanisms such as the Safety Parameter Display System (SPDS), and dose assessment methodologies.
The requirement for a licensee to hold an exercise on an annual basis is but one of many indicators designed to provide reasonable assurance that actions can and will be taken during an emergency situation that will provide for the health and safety of the public.
The technical basis for the exemption request, provided below, demonstrates that past performance, 1992 drill performance which separately meets the intent of the regulation, along with emergency preparedness initiatives, provides adequate justification for the granting of this request.
DISCUSSION The Company's emergency preparedness program is comprised of three integrated components. Emergency plans are in place for Surry Power Station, North Anna Power Station, and the Corporate Emergency Response Organization. The Corporate Emergency Response Plan is designed to be implemented in support of either or both stations and is exercised with each full demonstration of either station plan. Under existing regulations, a significant portion of the emergency response capability is repeatedly demonstrated with each annual exercise and was exercised in 1992 with the North Anna Power Station Emergency Exercise. This annual inspection of the North Anna Pqwer Station 1992 Emergency Exercise was completed in the first quarter of the year.
Demonstration of major elements of the plans are also Page 1 of 7
- documented through the design and conduct of drills and exercises at each plant site and at the corporate level for a combined total of seven times in 1992 as shown in. Taken together with the drills performed at Surry, which separately meet the intent of the rule, we contend that the Company has fulfilled the intent of the requirement to annually exercise its emergency plan without having to reexercise emergency plans again at Surry Power Station as scheduled in November, 1992. The annual Surry exercise will continue as scheduled in 1993.
Emergency planning regulations have been in place for over ten years and associated training programs have been in place and improved upon during the same timeframe.
These regulations were intended to lay the basis for a structured formal response capability and to ensure a continued elevated emphasis on emergency preparedness.
The Surry Power Station annual evaluated exercise is only one of many indicators designed to provide reasonable assurance that actions can and will be taken during an emergency situation that will provide for the health and safety of the public.
TECHNICAL BASIS The NRC periodically assesses the emergency preparedness of each licensee through use of the Systematic Assessment of Licensee Performance (SALP) to ensure an appropriate level of management attention and involvement. The latest SALP performance in emergency preparedness is the third consecutive Category 1 performance in this area at Surry. The last SALP period for the Surry Power Station covered the period from March 31, 1991 through April 4, 1992. The SALP Report (Reference 1 ), stated that Surry "... continued to maintain an excellent emergency preparedness program... " and that "[m]anagement support was evident throughout the period as the licensee continued to maintain in a state of readiness the basic emergency preparedness elements needed to implement the Emergency Plan and its procedures in response to emergency events." Furthermore, the report stated that
"[t]he licensee continued to build on a strong emergency response capability through numerous self-initiated program enhancements."
During the last Surry SALP period, two NRC emergency preparedness inspections were conducted. No violations or exercise weaknesses were identified. The first inspection was conducted during the Surry annual exercise held during the week of August 26, 1991 (Reference 2). The exercise was an extensive three day ingestion pathway demonstration. During this exercise, Surry's response capability was tested well beyond that of a routine graded exercise. The Company not only successfully demonstrated the adequacy of its own emergency response program, but also demonstrated the ability to provide coordinated support to the Commonwealth of Virginia's sampling plan and ingestion pathway operations, while at the same time responded with the State and the City of Newport News to an actual transportation event (Reference 3). The second NRC inspection was conducted during the week of February 24, 1992 (Reference 4).
That report states that "... the emergency preparedness program was found to be maintained in an adequate state of operational readiness." Additionally, three program strengths were identified "... with respect to training, management control systems, and independent audits."
Page 2 of 7
Similarly, an NRC inspection of the North Anna Power Station 1992 Emergency Exercise identified no violations or deviations (Reference 5). The NRC noted that full participation exercise, which was also evaluated by FEMA, demonstrated "[t]he licensee's... ability to implement the Emergency Plan and Implementing Procedures in a manner which provided adequate protection of the health and safety of the public and site personnel. Exercise strengths included a challenging scenario, a well-trained controlling staff, and a thorough critigue process." (emphasis added).
North Anna's latest SALP, covered the period from September 1, 1990 through November 2, 1991, and resulted in a repeat Category 1 rating. The report further confirms our sustained commitment and positive performance in emergency preparedness (Reference 6). The NRC cover letter transmitting North Anna's SALP ratings stated that with respect to emergency preparedness, the Company had
"... maintained their superior level of performance" and that "... [i]mproved performance in several activities was influenced significantly by initiatives implemented during the assessment period... " The SALP report identified six program strengths and discussed Company initiatives regarding enhancements, as well as taking "... the initiative (during) this assessment period to install an Emergency Response Data System (EROS) well in advance of EROS becoming a regulatory requirement." (See Page 15). These regulatory observations confirm the state of operational readiness at an overall Company level.
Since the Quality Assurance Audit/50.54(t) Review (QA Audit) for 1991 was found to be a strength at Surry during the NRC inspection in February (Reference 4), it is appropriate to briefly discuss the particulars of the program. The 1991 and the 1992 QA Audits were each conducted over a six week period, expended more than one man-year of effort and examined the overall Emergency Preparedness Program at both the station and corporate levels. This six week time period does not include team member preparation time nor does it include the time spent on the consolidation of the Audit Report and of follow-up actions taken by Quality Assurance Department personnel performed after the audit.
The 1991 QA Audit (No. 91-1 O) included the participation of seven Quality Assurance auditors and one specialized consultant. The completed audit checklist exceeded 200 pages. The 1992 QA Audit (No. 92-08) was conducted from April 14, 1992 through May 27, 1992.
This audit/review was conducted by six QA personnel and one consultant.
As previously mentioned, emergency planning regulations promulgated as a result of the accident at TMI govern virtually all aspects of an emergency response capability. It is important to note that with the use of improved training mechanisms and the establishment and maintenance of automated accident assessment systems, the emergency response capability of each licensee has been greatly enhanced over the past ten years with respect to an increased response level and structure. Specifically, the use of a Control Room Simulator during drills and exercises has resulted in an increase of realism during exercise play. The use of a Safety Parameter Display System and, in our case, the use of the Meteorological Information and Dose Assessment System (MIDAS) serve to provide an increased level of response. The Page 3 of 7
use of these systems during training has served to significantly enhance the capability of the emergency response organization to respond to an emergency situation.
The Company maintains a Drill and Exercise program that ensures the major elements of the emergency plan are verified and tested at a frequency equal to or, in many instances, in excess of, the frequencies specified by regulations and inspection guidance. This program is designed to establish and maintain a projected five year schedule and six year plan.
It is inclusive of semi-annual, annual, five year requirements, and six year (FEMA) requirements, to ensure demonstration of the major elements of the emergency plans. The drills and exercises conducted as a part of this program during 1992 have separately met the intent of the Appendix E,Section IV.F.2, requirement to exercise the Emergency Plan annually.
Demonstration of major elements of the plans are documented through the design and conduct of drills and exercises at each plant site and at the Corporate level several times each year. Drill and exercise scenarios include, as part of the overall process, the incorporation of required drills (e.g., annual Post Accident Sampling System and semi-annual radiation monitoring).
Additionally, drill and exercise scenarios are designed to ensure that training and emergency response activities closely approximate real events (e.g., the use of a Control Room Simulator and the loading of scenario data onto MIDAS) and that actual hands on experience is maintained by actual use of emergency communications equipment, equipment mock-ups, and the performance of walk-throughs of tasks required to be performed.
Further substantiation of our ability to protect the health and safety of the public is documented by an established critique process which evaluates equipment, procedure, and emergency response personnel performance demonstrated during the conduct of drills and exercises. This process is the same for drills as that employed during the conduct of annual exercises. Specific and detailed critique criteria, relative to drill and exercise objectives and performance criteria, are established and implemented to document an objective assessment. The results of the critiques are reviewed with station management and identified open items are tracked for resolution. This process was considered a strength during recent Surry and North Anna exercise inspections.
The foregoing discussion of initiatives, assessment mechanisms, training practices, reviews and inspections, and other performance indicators supports our exemption request in that an equivalent response level will continue to be maintained and the intent of 1 O CFR 50, Appendix E.IV.F.2, has been met. Furthermore, we contend that the full participation exercise conducted for the North Anna Power Station and evaluated by the NRC along with drills conducted at Surry Power Station are sufficient to demonstrate the emergency response capability of our Company for 1992.
Our request is implicitly supported by another part of the Code of Federal Regulations.
44 CFR 350.9, by virtue of its stated requirements for offsite response organizations, recognizes that within the context of that regulation, the biennial conduct of an exercise is sufficient to demonstrate that protective measures can and will be taken in the event of an accident thereby providing reasonable assurance of the health and safety of the public.
Page 4 of 7
CONCLUSION Granting a one-time exemption from conducting the scheduled annual emergency exercise at the Surry Power Station on November 18, 1992 is warranted based on the present level of emergency preparedness, past performance, and by virtue of meeting the intent of the regulation by previously conducted emergency drills.
JUSTIFICATION 1 O CFR 50.12 states that the Commission may grant exemptions from the requirements of the regulations contained in the 1 O CFR 50 provided that: (1) the exemption is authorized by law, (2) the exemption will not present an undue risk to the public health and safety, (3) the exemption is consistent with the common defense and security, and (4) special circumstances as defined in 1 O CFR 50.12(a)(2) are present.
- 1.
The Reguested Exemption is Authorized by Law No law exists which would preclude the activities covered by this exemption request, thus the Commission is authorized to grant this exemption.
- 2.
The Requested Exemption Does Not Present an Undue Risk to the Public Health and Safety
- 3.
The one-time exemption from the requirement to annually exercise the emergency plan at each site does not present an undue risk to the public health and safety.
A significant portion of the Company's emergency response capability has been evaluated by the NRC during the North Anna graded exercise. The exercise of Surry specific aspects of the emergency plan has been conducted through the Drill and Exercise Program and separately meets the intent of the regulation.
No plant components are affected by this exemption. Therefore, an exemption from the Surry annual exercise does not increase the risk to the public health and safety.
The ReQuested Exemption Will Not Endanger the Common Defense and Security The common defense and security are not an issue in this exemption request.
- 4.
Special Circumstances as Defined in 1 o CFR 50.12(a)(2)
The following special circumstances pursuant to 1 O CFR 50.12(a)(2) are identified as applicable to this exemption request:
Item (ii) - "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." As discussed above, we contend that the underlying intent of the rule is already met by the programmatic features and sustained excellent performance of the Company emergency preparedness Page 5 of 7
program.
Requiring the scheduled annual exercise at Surry is merely duplicative confirmation and unneeded to establish an assessment of the adequacy of the emergency preparedness program.
Item (v) - "The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation." A one-time exemption, based on already established performance is not permanent, but rather provides relief only for 1992. The performance to date has shown "good faith" to comply with the intent of the regulation.
Item (vi) - "There is present any other material circumstances not considered when the regulation was adopted for which it would be in the public interest to grant an exemption... " The regulation obviously could not account for the general improvements in all areas of emergency preparedness including training, organization, equipment, and facilities put in place since Appendix E was incorporated twelve years ago. Furthermore, the overlap of emergency planning structure and organization for multi-plant utilities was not adequately addressed in the original regulation nor was any accounting for sustained performance taken into consideration. These "other circumstances" provide an additional basis whereby the public interest would be served by applying resources directed to duplicating confirmation to other safety priority issues.
SAFETY IMPACT Virginia Electric and Power Company has reviewed this exemption and determined that the exemption of the Surry Power Station November 1992 annual emergency exercise will not impact nuclear safety. This exemption request provides a one-time exemption of the annual exercise evaluation requirements. Thus, operation of the Surry Power Station in accordance with this request will not:
- 1.
Involve an increase in the probability of occurrence or consequences of any accident or malfunction of equipment which is important to safety and the UFSAR. Elimination of the annual emergency exercise at Surry has no bearing on the probability of accident occurrence. Likewise, it has no bearing on the consequences of an accident as analyzed in the UFSAR. Furthermore, as noted in the request, elimination of the annual exercise on a one-time basis does not reduce the effectiveness or response capabilities to an accident as evidenced by the organizational performance demonstrated to date.
- 2.
Create the possibility of a new or different type of accident from those previously evaluated in the safety analysis report. Physical plant modifications are not being made and plant operations are not being changed. Since elimination of the 1992 annual emergency exercise has no bearing on initiation of accidents at the plant, no new accident precursors are being generated and therefore no new or different kind of accident is created by this request.
Page 6 of 7
- 3.
Involve a reduction in the margin of safety. Plant operations are not being changed nor are any of the accident analysis assumptions being modified or exceeded by this exemption request. The exemption from the 1992 annual exercise will not affect any plant equipment. Therefore, the accident analysis assumptions remain bounding and safety margins remain unchanged.
Furthermore, as noted above, elimination of the 1992 emergency exercise at Surry does not reduce the effectiveness or response capabilities of the emergency plan.
Page 7 of 7
ATTACHMENT 2 VIRGINIA POWER NUCLEAR EMERGENCY PREPAREDNESS 1992 DRILL AND EXERCISE SCHEDULE North Anna Power Station Mid January 1992 (GE-F)
May 20, 1992 (TRN-RM)
June 24, 1992 {TRN)
Surry Power Station March 31, 1992 (TRN-RM)
September 16, 1992 (CFO-RM)
November 4, 1992 (DR)
July 15, 1992 (TRN-CCD)
September 30, 1992 (RM)
December 9, 1992 (FERC)
- November 18, 1992 (GE)
Legend:
CCD INPO Casualty Control Drill CFO Combined Functional Drill DR Dress Rehearsal Exercise F
FEMA Evaluated FERC Hydro-electric Project Communications Exercise GE Graded Exercise RM Radiological Monitoring Drill TRN Training Exercise This exercise is the subject of the exemption request.
ATTACHMENT 3 REFERENCES
- 1.
NRC Inspection Report 50-280, 281/92-10 dated June 9, 1992
- 2.
NRC Inspection Report 50-280, 281/91-25 dated October 1, 1991
- 3.
Virginia Power Reactor Coolant Pump Motor Accident Report dated August 27-30, 1992
- 4.
NRC Inspection Report 50-280, 281/92-05 dated March 18, 1992
- 5.
NRC Inspection Report 50-338, 339/92-01 dated February 12, 1992
- 6.
NRC Inspection Report 50-338, 339/91-25 dated January 13, 1992
Virginia Electric and Power Company's Drill and Exercise Program. We believe this to be an unnecessary use of Federal, Company, State and local resources that would only serve to reconfirm the established adequacy of the plan as well as the Company's capability to implement the plan.
Resource savings to Virginia Power alone is estimated to be in the range of $200,000 per annual exercise. Performance of the 1992 Surry Emergency Plan exercise, given our specific circumstances and performance in this area, represents an undue regulatory burden with minimal benefit to publi~ safety.
1 O CFR Part 50.12 permits the Nuclear Regulatory Commission (NRC) to grant exemptions from requirements in 1 O CFR Part 50 for special circumstances as described in 1 O CFR Part 50.12(a). One such special circumstance is provided for instances as when the application of a regulation "... would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule."
In this case, the requirement to perform the November 1992 Surry Power Station Emergency Plan exercise is not necessary to achieve the underlying purpose of the emergency preparedness rule because the intent of the rule has been achieved by virtue of the emergency preparedness performance year-to-date. Furthermore, the requested exemption will not adversely affect the overall state of emergency preparedness at Surry Power Station.
Justification of this exemption request is based on demonstrated performance as evidenced through several assessment mechanisms. These mechanisms include the Systematic Assessments of Licensee Performance and our in-depth Quality Assurance Audit/50.54(t) Review Program. In addition, we obtain an independent assessment of performance whenever necessary.
Justification is also based on training programs for personnel and a Drill and Exercise Program, for which the drills conducted in 1992 have met the intent of the regulation for annual exercise of the Emergency Plan. These components of our program are designed to maintain a high standard of emergency preparedness.
These assessments and programmatic features establish that the emergency plan has been and will continue to be effectively maintained and exercised during 1992 and that an exemption from the required performance of the scheduled November 1992 annual exercise is warranted. Finally, Virginia Electric and Power Company conducted the 1992 Emergency Plan annual exercise at North Anna Power Station during the first quarter. This exercise was evaluated by the NRC, and found satisfactory.
This request has been discussed with the Department of Emergency Services of the Commonwealth of Virginia. They have expressed no objection to the request.
For these reasons, we conclude that the requested exemption will not present an undue risk to the public health and safety and is consistent with the common defense and security, and meets the special circumstance described in 1 O CFR Part 50.12(a)(2)(ii).
We would appreciate your review of this request prior to the currently scheduled November 18, 1992 Surry Power Station Emergency Plan exercise. To facilitate your review, we are prepared to meet with you at your earliest convenience. In addition, we are considering a similar one-time exemption request for the North Anna Power