ML20056F430

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Provides Results of Review of Rev 14 to Emergency Plan. Concludes That One EAL Changes Reduced Effectiveness of EAL by Deletion of Indicator to Assist CR Operators in Determining in Emergency Should Be Declared
ML20056F430
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 08/09/1993
From: Cline W
NRC Office of Inspection & Enforcement (IE Region II)
To: Stewart W
Virginia Power (Virginia Electric & Power Co)
References
NUDOCS 9308270220
Download: ML20056F430 (4)


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/*US G 0 jgg3 Docket Nos. 50-338, 50-339 License Nos. NPF-4, NPF-7 Virginia Electric and Power Company ATTN: Mr. W. L. Stewart Senior Vice President - Nuclear 5000 Dominion Boulevard Glen Allen, VA 23060 l

Gentlemen:

SUBJECT:

NORTH ANNA POWER STATION EMERGENCY PLAN REVISION 14 We have completed our review of the subject submittal.

Based on our review, we have concluded that one of your emergency action level (EAL) changes reduced the effectiveness of the EAL by the deletion of an indicator to assist the Control Room Operators in determining if an emergency should be declared.

This item was discussed between members of your staff and NRC staff during a teleconference call on July 23, 1993. The specific initiating coadition (IC) l and EAL are discussed in the Enclosure. -You must not continue to implement j

the referenced change. Please modify your Plan to correct the appropriate page or provide additional details to justify the EAL change. We request that the corrected page(s) or additional justification be provided to us within 45 days l

of the date of this letter.

It is our understanding that you are developing a technical basis document for the EAls which may result in additional changes to your existing EALs. In addition, members of your staff indicated that the appropriateness of the acoustic monitoring capability would be further reviewed and responded to as necessary. If your understanding on this matter is different from that discussed, please contact this office -immediately.

Should you have any questions regarding tM-ietter, please contact Mr. Kenneth P. Barr of our staff at ('.G4) ?M-0335.

Sincerr:iy, c

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William E. Cline, Chief Radiological Protection and Emergency Preparedness Branch Division of Radiation Shfety and Safeguards

Enclosure:

(See page 2) 9308270220 930e09 17

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Virginia Electric and Power Company 2

Enclosure:

Emergency Action Level l

cc w/ encl:

M. L. Bowling, Jr., Manager Nuclear Licensing Virginia Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 G. E. Kane, Station Manager North Anna Power Station P. O. Box 402 Mineral, VA 2311'?

Executive Vice President Old Dominion Electric Cooperative 4201 Dominion Boulevard Glen Allen, VA 23060 Dr. W. T. Lough Virginia Corporation Commission Division of Energy Regulation P. O. Box 1197 i

Richmond, VA 23209 William C. Porter, Jr.

County Administrator Louisa County l

P. O. Box 160 Louisa, VA 23093 Michael W. Maupin, Esq.

Hunton and Williams Riverfront Plaza, East Tower 951 E. Byrd Street Rid 3mond, VA 23219 Attorney General j

Supreme Cotet Building 101 Nortn 8th Street Richmond, VA 23219 Robert B. Strobe, M.D., M.P.H.

State Health Commissioner Office of the Commissioner Virginia Department of Health P. O. Box 2448 Richmond, VA 23218 bcc w/ encl:

(See page 3) l l

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Virginia Electric and Power Company 3

bec w/ encl:

G. Belisle, RII l

L. Engle, NRR Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 78-A Mineral, VA 23117 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 1, Box 166 Surry, VA 23883 1

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ENCLOSURE EMERGENCY ACTION LEVEL Appendix 10.11 INITIATING CONDITIONS EMERGENCY ACTION LEVELS Page 10.11.2, Initiating Conditions: Notification of Unusual Event The emergency action level (EAL) for the initiating condition " Failure of a safety or relief valve to close after pressure reduction, which may affect the health and safety of the public", was revised as follows:

i RCS Pressurizer safety or PORV flow a, 7dicated by temperature monitoring equipment with RCS pressure less tha, '500 psig OR Main Steam i

Excessive Steam Generator Safety, PORV or Decay Heat Release flow as indicated by rapid RCS cooldown rate with Main Steam pressure greater than 100 psi below setpoint of affected valve.

l The previous EAL read "Either condition a) or b) exist:

a) RCS, pressurizer safety or PORV flow as indicated by acoustical or temperature monitoring equipment and RCS pressure is less than 1600 psig b) Main Steam (MS), Excessive Steam Generator Safety, PORV or Decay Heat Release flow as indicated by rapid RCS cooldown rate i

and MS pressure is greater than 100 psi below set point of affected valve"

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The deletion of the acoustical monitoring capability from the revised EAL reduced the effectiveness of the EAL due to the removal of a positive indicator for determining valve position. As a Post-TMI action item, licensee's were required by NUREG-0737 (Item II.D.3) to provide the Control Room Operators with unambiguous indication of valve position so that appropriate actions can be taken. The combination of acoustical and temperature indicators rather than temperature only, would provide the Control Room Operators with more prompt, adequate, and reliable information to determine if an emergency should be declared. The revised EAL increases the potential for human errors and delays in event recognition. This approach to event declaration is not consistent with the intent of NUREG-0654 regarding early and prompt recognition and noti.*ication of minor events which could lead to more serious conditions which are not yet fully realized. This issue was discussed with members of your staff on July 23, 1993.

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