ML20235W579

Requests Exemption from Requirements of 10CFR50.47 & App E Re Performance of Exercise of Emergency Plan in 1987 Per 10CFR50.12 & in Light of Action Taken in Response to 870715 Steam Generator Tube Rupture Event

ML20235W579
Person / Time
Site:	North Anna
Issue date:	10/09/1987
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
87-472B, NUDOCS 8710160319
Download: ML20235W579 (3)

Text

i a

VIItOINIA 13LECTRIC AND l'OWEH COMPANY UbkkC.gg Rrenxonn,VIHOINIA 20261 h) gCI U A u pg October 9, 1987 W.L.srs = ,,

mL*1"l;.".'::,"L.

United States Nuclear Regulatory Commission Serial No. 87-472B Attention: Document Control Desk N0/DJV:jmj Washington, D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPAN_Y NORTH ANNA POWER STATION UNITS 1 AND 2 RE0 VEST FOR ONE TlviE EXEMPTION FROM ANNUAL EMERGENCY EXERCISE RE0VIREMENT By letter dated August 3,1987, Virginia Electric and Power Company requested that the emergency actions taken by the Company in response to the North Anna Unit I steam generator tube rupture (SGTR) event on July 15, 1987 be accepted as satisfying the annual Emergency Plan exercise requirement for 1987. Our letter dated September 11, 1987 provided supplemental information regarding this request. A meeting was subsequently held on September 29, 1987 between representatives of our respective staffs to discuss this issue. As agreed during this meeting, the purpose of this letter is to formally request an exemption, in accordance with 10 CFR 50.12, from the requirement of 10 CFR 50.47 and Appendix E to perform an exercise of the Station Emergency Plan in 1987.

Exemotion Reouest l

Virginia Electric and Power Company requests an exemption from the requirement j to conduct the annual exercise of the North Anna Emergency Plan in 1987. This request is based on our demonstration, during the SGTR event, that the l 3

Emergency Plan is adequate and capable of being implemented, and that the j state of our emergency preparedness provides reasonable assurance that l adequate protective measures can and will be taken in the event of a radiological emergency. Approval of this exemption request is needed to avoid the duplication of conducting an exercise, and therefore the unnecessary use  ;

of Company, State and local resources, that would only confirm the adequacy of 1 the plan as well as the Company's capability to implement the plan, that have already been demonstrated during the SGTR event. The conclusion that our response to the SGTR event fulfilled the requirements of an annual emergency )

plan exercise is based on the supporting information provided to the NRC in j j our letters dated August 3,1987 (Serial No.87-472) and September 11, 1987 '

l N rial No. 87-472A).

I 1

8710160319 871009 DR ADOCK 050 B g63 f i

/[0

The justification for this exemption request is provided below in accordance with 10 CFR 50.12. Furthermore, information is also provided in accordance with 10 CFR 51.30 which supports the conclusion that approval of this  !

exemption request would not have an effect on the environment. '

Justification for Exemotion l l

10 CFR 50.12 permits the NRC to grant exemptions from the requirements in 10 j CFR Part 50 for special circumstances as described in 10 CFR 50.12(a)(2). One  !

such special circumstance is when the application of a regulation ". . . would I not serve the underlying purpose of the rule or is not necessary to achieve i the underlying purpose of the rule." In this case, the requirement to perform l an exercise of the North Anna Power Station Emergency Plan in 1987 is not '

necessary to achieve the underlying purpose of the emergency preparedness rul e. This is because the emergency plan has been adequately exercised and i demonstrated in 1987 by our response to the SGTR event.  !

We have determined that our response to the event demonstrated the same key elements of our Emergency Plan as would have been demonstrated by conducting the preplanned emergency exercise. These key elements are described in Section IV.F.2 of 10 CFR 50 Appendix E. Specifically, the event demonstrated the adequacy of our Emergency Plan Implementing Procedures, of our emergency facilities and equipment, and of our communications systems. In addition, the familiarity of our emergency response personnel with their duties was demonstrated. The event did not test the public notification system. However the public notification system is routinely tested at least four times each year. Also, the preplanned emerg3ncy exercise for 1987 did not have as one of its objectives a test of the public notification system.

Environmental Assessment - Supportino Information Environmental Impact of the Proposed Action:

An annual Emergency Plan exercise would not be conducted for the North Anna Power Station if the requested exemption was granted by the NRC. Whether or not an exercise is conducted, the environment is not impacted since neither case involves the release of radioactive or non-radioactive effluents.

Furthermore, the NRC had determined that an environmental impact statement for 10 CFR 50.47, " Emergency Plans," and 10 CFR 50 Appendix E, " Emergency Planning and Preparedness for Production and Utilization Facilities," in which the requirement for an annual emergency plan exercise is contained, was not required (45FR55402, August 19, 1980). Specifically, the NRC's " Draft Negative Declaration; Finding at No Significant Impact" (45FR3913, January 21, i 1980), states that ". . .the impacts on the human environment of the proposed l rule will be insignificant . . . . "

Therefore, not conoucting an annual l emergency plan exercise as required by the rule will have no impact on the human environment.

l Alternatives to the Proposed Action: "

The previous section provides the basis for concluding that there are no i

environmental effects which would result from approval of the requested exemption. Accordingly, any alternatives with any environmental impact need not be evaluated.

The only remaining alternative is to deny this exemption. Since we have shown that granting this exemption would not result in any environmental impact, denial of this request would only result in requiring Virginia Electric and Power Company to demonstrate certain capabilities under " drill" conditions that were .already successfully. demonstrated under " actual" conditions. Also, i

denial of this request would result in the additional expenditure of State and l local emergency response agencies' and Company resources over that which has already been expended in responding to the SGTR event.

Alternative Use of Resources:

The proposed action does not involve the use of environmental resources, and therefore does not involve the use of resources not previously considered in the Final Environmental Statement (as amended) for the North Anna Power Station, Unit Nos. 1 and 2.

Proposed Finding of No Significant Impact:

Based upon the foregoing environmental assessment, we conclude that approval of our exemption request will not have an effect on the quality of the human i environment.

Additional Supportina Information During the September 29, 1987 meeting, our critique of the Company's response to the SGTR event was discussed, and several issues were raised which had not been addressed in our previous letters on this subject. With the exception of the issue concerning the maintaining of a positive pressure within the control room envelope, each of the issues raised in the meeting is addressed in our detailed report on the event, " North Anna Unit 1 July 15,1987 Steam Generator Tube Rupture Event Report," revision 1, submitted to the NRC on September 15, 1987. The control room pressure envelope issue was addressed in our letter to the NRC dated September 11,1987 (Serial No. 87-2888). ,

l Should you require any additional information, please contact us.

]

Very truly yours, kk W. L. Stewart I

cc: U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.

Suite 2900 Atlanta, GA 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station

._-_ - _ _ _ _ _ _ _ . ._ .