ML20150F471

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Exemption from Requirements of 10CFR50.12(a) Re Conduct of Exercise of Plant Emergency Plan in 1987.Underlying Purpose of Regulation Achieved Through Util Response to 870715 Steam Generator Tube Rupture Event
ML20150F471
Person / Time
Site: North Anna  
Issue date: 03/28/1988
From: Varga S
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20150F474 List:
References
NUDOCS 8804050226
Download: ML20150F471 (9)


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7590-01 tlNITED STATES OF AMERICA NUCLEAR PFGillATORY COMMISSION i

In the Matter of

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Docket Nos. 50-338 i

and 50.'30 VIRGINIA ELECTRIC AND POWER COMPANY

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North Anna Powar Station, tinits 1&P

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I EXEMPTION 1.

Virginia Electric and Pnwer Company (the licensee) is the holc'er of Facility Operating License Nos. NPF-4 and NPF-7, which authorire operation of North Anna Power Station, Units 1 and 2 (the facility) at steady-state reactnr power levels for each unit not in excess of P905 megawatts thermal.

The license provides, among other things, that it is subject to all rules, regula-tions and Orders of the Nuclear Regulatorv Comission (the Commission or NRCI now or hereaf ter in effect.

The facilities consist of two pressurized water j

4 reactors incated at the licensee's site in Louisa Countv, Virginia.

9804050226 880328 ADOCK 050 0

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2 II.

Section 50.54(c' nr 10 CFR Part 50 requires a licensee authorized to operate a nuclear power reactor tn follow and maintair in ef#ect emergency plans which meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50 S'ection IV.F.? of Apoendix E requires that each licensee at each site shall annually exercise its emercancv plan.

The NRC may grant exemptions from the requirements of the regulations which, pursuant to 10 CFR 50.1?(a), are (1) authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security; and (?) present special circunstances.

Section 50.1?f allM(MI of 10 CFR Part 50 describes the special circumstances for an exemption where the application of the regulation in the particular circum-stances would not serve the undarlying puroose of the rule or is not necessary to achieve the underlying purrese of the rule. The underlying purpose of Appendix E,Section IV.F.? is to demona+ rate that the emergency plan is ade-i auate and capable of being implemented, and that the state o' energenev preparednats provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

III.

By letter dated October 9,1987, the licensee requested an exemption from the requirements of 10 CFR 50.47 and Appendix E to conduct an annual exercise of the North Anna Emergencv Plan in 1987. The licensee had planned to conduct an exercise nf its emergency plan on August 4, 1987 with the partial participa-tion of State and incal emergency retponse organizations. The scheduled J

3 exercise was an annual licensee off-year exercise and the r deral Emargency e

Management Agency (FE5'Ai was not scheduled to observe the exercise. The pre-vious emergency preparedness exercise at the North Anna Power Station, conocct-ed on June IR, 1986, was a full participation biennial exercise. The licensee requested that an exemption be aranted because the requirement to perform an exercise of the North Anna Emeroency Plan in 1087 was not necessarv to achieve the underlying purpose of the emergency planning rule in that the emergency plan was adequately exercised and demonstrated in 1987 in the licensee's re-sponse to the Unit 1 steam generator tube rupture (SGTR) event that occurred on July 15, 1987 The schedule for future exercises will not be affected by 8

this ore-time exemption.

To support their raouest, the licensee provided the following information in submittals to the NRC dated August 3, 1987 and Seotember 11, 1987.

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Key elements of the North Anna Power Station emergency plan demonstrated durina the SGTR event.

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An overviaw of emergency response activities.

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Description /secuence of events, including specific emeroency response, classification and action, d.

Extent of involvement of offsite agene.ies.

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A discussion of the emeroency response critique conducted after the event.

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A cross-reference between the emergency plan elements carried out during the SGTR event and NUREG-0654/ FEMA-REP-1 criteria.

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In these submittals and in a presentation to the NPr sta'f on September P9, 1987, the licensee provided extensive documentation concerning their initial i

emeroency response and followup actions to the SGTR event.

On July 15, 1987, at 6:25 a.m., North Anne l' nit 1 experienced a steam i

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generator tube rupture while operating at 100% power. The unit was manually

' tripped by the operators, which was followed by safety in.iection actuation. A small radioactive release to the environment occurred during the course of the event.

An Unusual Event was declared at 6:39' a.m., and the emergency classifi-2 cation was upgraded to an A'ert at 6:54 a.m.

The licensee downgraded the emer-cency classification from Alert to Recovery when the unit reached a cold shut-down condition et 1:31 p.m.

In response to the SGTR event, the following key elements of the North

'Anra emergency plan were deronstrated:

j Classification o# the event in accordance with the emeroency plan imple-l menting procedures.

l Notification of State, local and Federal emaraencv resoonse organizations i

and personnel.

I Activation, staf'ing and operatinn of the emergency response facilities j

including the Control Room, Technical Support Center, Operational Support a

j Center, local Emergency Operations Facility, Corporate Fmergenrv Response i

l Center, Corporate Public News Center and Local Media Center.

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5 Communications between emergency facilities, princioal resoorse nraaniza-tions and energency oersonnel.

Accident assessnent invo'ving the metheds, systems and equipment necessary 4

for assessing and monitoring the actual consequences of the event, including both an engineering assessment of plant status and an assessment of radio-Icgical consequences.

Pedia and public in#0rmation dissemination through the issuance o' press releases and the conduct of press briefings at the Corporate Public News Center and Local Wedia Center.

Recovery planning, including the fomation of a recovery organization, l

identification of resources and the development of recovery actions.

Licensee response activitier included the developrent of initial and

'ollowup nessaaes (17 totali to offsite organizatiers, continuous communication with the NRC, station accountability, securitv access control, dispatch of i

inplant, onsite and offsite monitoring teams, formulatine of offsite dose pro-4ections, including the determination of meteorological discersion, collertior ard analysis of environmental samples, analysis of inplant radioactivity levels, and interfacing with State emergency operations personnel at the Corporate Emergencv Response Center. Although protective action recommendations for the public were not required to be issued based on plant parameters and field moni-toring information, the necessity for issuing such reconmendations was con-l sidered by the licensee during the course of the event.

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6 After the SGTR event, the licersee conducted interviews of personnel in-volved in the emergency response effort.

Based upon these interviews, the licensee developed a list of 10 corrective actions resulting from the irple-nentatien of the North Anna Emergency Plan under actual conditions.

In a letter to the NRC dated Decer.ber 4,1987, the licensee committed to assure completion of these corrective actions no later than the next anrual emergency plan exercise.

In addition to the response to the SGTR event, other licensee activities related to the demonstration of preparedress in 1987 included a practice exer-cise conducted on iluly 14, ?0o7 with some offsite participation, the conduct of fire and medical drills or. August 13, 1987, and a post-accident sampling system (PASS) dri11 on August 14, 1987 The fire, medical and PASS drills were originally te be held in con,iuncticn with the scheduled exercise.

In the December 4,1987 letter to the NRC, the licensee listed the items resulting from the critiques of the fire, redical and PASS drills, and committed to complete the identified corrective actions prior to the next annual exercise.

The rest recent NRC Systematic Assessment of Licensee Performance (SALP)

Report for North Arna, issued on December 1.1, 1986 for the period March 1, 1985 through August 31, 1985, indicated satisfactory overall licensee rerformance.

Specifically, in the functional area of emergency preparedness, licensee perfor-mance was rated as Category 2, indicating a satisfactory level of perforwance.

Inspection activities conducted since the SALP report have confirmed that the licensee has maintained a satisfactory level of performance regarding emergency preparedness.

7 The Commonwealth of Virginia has indicated its suppnrt for the licensee's request for an exemption in a letter to the licensee dated September 8,1187 The State noted that the local governments and State agencies had achieved the ob,iectives of the original scheduled exercise.

The State indicated that the response to the actual event was of more value to the State agencies and local governments for training purposes than the simulated accident would have been, Copies of the State's report of the radiological emergency at North Anna were provided by the State to the Federal Emergency Management Agencv.

IV.

4 Based on a review of the licensee's request for an exemption from the recuirement to conduct an exercise of the North Anna Fmergency Plan in 1987, the NRC staff finds that the underlying purpose of the regulation has been achieved through the licensee's response to the SGTR event which occurred on July 15, 1987 The licensee fui y activated and staffed all of its emergency t

response 'acilities and performed all necessary respnnse actions under actual conditions.

Both onsite and effsite emergency response organizatiers were involved in the event. The response to the SGTR event tested the adecuacy o' the emergency plan implementing procedures, tested emergency equipment and conmunications networks, and provided a unique opportunity to ensure that emergency organization personnel were familiar with their duties. The licersee has identified corrective actions to improve the level of emergency preparedness at North Anna through interviews with emergency personnel followinq the event.

NRC Region II will assure that these corrective actions are completed on a schedule cornitted to by the licensee. The staff concludes that the licensee i

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satisfactorily demonstrated the adecuacy of the North Anna Eriergency Plan and its capability of beina implemented in the response to the SGTR event on July 15, 1987.

Thus, a 'urther exercise in 1987 was not necessary to achieve the underlying purpose of the rule. The requested exemption from the requirement 4

of 10 CFD Part 50, Appendix E Section IV.F, to perform an exercise of the North Arna Emergency Plan in 19P7, will not adversely affect the overall state of emerconey preparedness at the' North Anna site because the emergency plan was adequately exercised and demonstrated during the licensee's response to the July 15, 1987 tube rupture event.

For these reasons, the Comissinn has detemined that, pursuant to 10 CFR 50.12, tha exemption recuested by the licensee's letter dated October 9,1987, as discussed above, is authorizod by law, will not present an undue risk to the public health and safety, and is consistent with the corwon defense and security and that special circumstances are present as set forth in 10 CFR 50.12(a)(?Hiii.

Pursuant to 10 CFR 51.32, the Comission has determined that aranting of this Exemption will have no significant impact on the environment (March 28, 19EP, 53 FR 10002).

A copy of the licensee's request for exemption and supporting documentation is available for public inspection at the Comission's Public Document Room, 1717 H Street, NW, Washincton, DC and at the Board of Supervisors office, Louisa County Courthouse, Louisa, Virginia 23093 and the Aldeman Library, Manuscripts Department, University of Viroinia, Charlottesville.

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Virginia P2901.

Copies may be obtained upon written request to the U.S.

t Nuclear Regulatory Comission. Washington, DC 20555. Attention:

Director.

l Division cf Deactor Pro,iects I/II.

This exenntier is effactive upor isiterce.

Dated at Dockville, Maryland this 28th. day of >!srch 1988 F01 THE NUCL R REGutt. TORY C P ISSION

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Sfeven arga Dirac r Division of Reactor Pro. cts-I/II Office of Nuclear Reactor Reaulation i

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