ML19254D311

Memorandum of Proposed Findings Per Aslab 790621 Order. Predictions of Amount of Settlement Cannot Be Accurately Made.Tech Spec Limit on Amount of Settlement Is Acceptable.Nrc Should Review Operator Training Program

ML19254D311
Person / Time
Site:	North Anna
Issue date:	08/20/1979
From:	Gambardella A VIRGINIA, COMMONWEALTH OF
To:
References
NUDOCS 7910230660
Download: ML19254D311 (6)

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\ g9?' z3 ai t <gg? I UNITED STATES OF AMERICA \' , ei j NUCLEAR REGULATORY COMMISSION \ .s

$<7 2 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )

) Doc. Nos. 50-338 OL VIRGINIA ELECTRIC AND POWER COMPANY ) 50-339 OL

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(North Anna Power Station, Units ) (Pump House Settlement 1 and 2) ) and Turbine Missiles)

COMMONWEALTH OF VIRGINIA'S MEMORANDUM OF PROPOSED FINDINGS In accordance with the Atomic Safety and Licensing Appeal Board's memorandum and order of June 21, 1979 hee-Commonwealth of Virginia submits this memorandum./,7phe lWL N,

Commonwealth submits that the board's decision concerning the settlement of the Service Water Pump House at North Anna Nuclear Units 1 and 2 should include the following findings and conclusions.

I The Applicant concedes that predictions of the amount of settlement of the Service Water Pump House in the future cannot be made accurately (VEPCO Proposed Findings, pp. 5-7). As a result, measures to monitor the settlement of the pump house are necessary to assure that the settlement does not unexpectedly increase. It is recognize that operation of the facility should be modified or terminated in the event that continued settlement causes unacceptable stress 7 910'2 3 0 6'( C) 1189 342

to piping and other system components until repairs to the affected components are made. The NRC staff generally concurs in the regulatory approach proposed by the Applicant.

II Technical specifications attached to the operating license establish a limit on the amount of settlement which may occur before the Applicant must take remedial actions.

At 75% of the limit established by the technical coecification VEPCO must report to the NRC staff and p' gose corr (Jtive action, if necessary. At 100% of the limit established by the technical specification operation must be terminated and corrective action taken, if necessary. (VEPCO Testimony on Service Water Pump House Settlement, pp. 27-28). Both the NRC staff and the Applicant have concluded that the limit established by the existing license, is acceptable. (Amend-ment No. 12 to the North Anna, Unit No. 1 operating license) .

It appears that the physical facilities and the administrative restrictions as to operation proposed with respect to the settlement of the service water pump house are necessary to protect the public health and safety.

III The applicant's program to deal with the adverse effects of settlement on its operations in North Anna assumes that appropriate actions will be taken by its reactor operators Ii89 543 and other personnel in appropriate time sequences (TR. 181-85). The lesson of '.he Three Mile Island incident is that operator error, as well as equipment failure, must be avoided before the Appeal Board can conclude, as Vepco would have it conclude, that "On this evidence there is no reason to believe that the applicant will not comply with his technical specifications on settlement. In short, the record supports the conclusioi. that the settlement monitoring program will adequately protect the public health and safety and that full-power, full-term operating licenses for North Anna Units 1 and 2 may be issued." (VEPCO Proposed Findings, p. 27).

The Applicant may fully intend to comply with the requirements of its licenses and the regulations of the Commission.

However, operator error must be avoided in order to eliminate unintentional noncompliance with these requirements.

For the foregoing reasonr, reactor operators, shift supervisors, and other personnel should be required to complete an orientation and training program with respect to the specific instrument readings and other operational events which would indicate that there is a significant .

malfunction at the pump house. In a situation such as this one where a nuclear power plant has an unique abnormality which may effect its operations, the personnel who are employed at that facility should be trained to recognize the effects of that peculiarity of the plant, and to take remedial action, if necessary. Although the record reflects that operators at North Anna have been given training with respect 1189 344 to the pump house settlement (TR. 186), there is no indication that the staff has reviewed the details of that training.

The Board's decision should require the staff to review and approve periodically provisions in applicant's personnel training programs to assure that appropriate personnel are prepared to recognize any safety problem which may arise at the pump house. If such a review has already been conducted, the Staff should report the results of that review to the Board.

Respectfully submitted, COMMONWEALTH OF VIRGINIA By: -JM Assistan ' Attorney General Marshall Coleman Attorney General Anthony Gambardella Assistant Attorney General 11 S. 12th Street, Suite 308 Richmond, Virginia 23219 1187 345 i

CERTIFICATE OF SERVICE I certify that I have served a copy of Commonwealth of Virginia's Memorandum of Proposed Findings on each of the persons named below by first-class mail, postage prepaid:

Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION: Chief, Docketing & Service Section Daniel T. Swanson, Esquire U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard M. Foster, Esquire 1230A Pearl Street Denver, Colorado 80203 James N. Christman Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 Alan S. Rosenthal, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Michael C. Farrar, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1189 346

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety a::d Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

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• By I Anthony Gam brdella DATED: August 20, 1979 118') z47 D

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