ML18153B842

Responds to NRC 890629 Ltr Re Violations Noted in Insp Repts 50-338/89-14,50-339/89-14,50-280/89-17 & 50-281/89-17. Corrective Actions:Study Completed by Outside Consultant Identifying Improvements for Independent Review Process

ML18153B842
Person / Time
Site:	Surry, North Anna, 05000000
Issue date:	07/28/1989
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
89-495, NUDOCS 8908040229
Download: ML18153B842 (5)

Text

• VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, 0 VIRGINIA 23261 W."L. STEWART SENIOR VICE PRESIDENT POWER

• US Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

July 28, 1989 VIRGINm ELECTRIC AND POWER COMPANY SURRY-POWER STATION UNITS *1 AND 2 NORTH ANNA POWER STATION UNJTS l AND 2 NOTICE Of VIOLATION JEIR 50-338&339/89-14 VJOLATJON A IEIR 50-280&281/89*17 Serial No. NOS/TAH:jmj Docket No.

• License No.89-495 50-280 50-281 50-338 50-339 DPR-32 DPR-37 NPF-4 NPF-7 We have received your letter of June 29, 1989, which transmitted the Notice of Violations from Inspection Report 50-338&339/89-14 for North Anna Power Station. We have also received Inspection Report 50-280&281/89-17 for Surry Power Station which addressed similar concerns.

Our response to the Notice of Violation, for Violation A of IEIR 50-338&339/89-14, is attached.

The response to Violations Band C will be submitted under separate.cover.

As discussed in the attached violation response, to ensure that we are able to provide the required independent review activities and to provide appropriate management support, we have taken the necessary actions to bring us into compliance with Technical Specifications and to ensure that future independent review activities will meet both the letter and the intent of the technical specifications.

These actions include a rededication of the Director -Safety Evaluation and Control's responsibility to supervise and oversee the Independent Review group's activities.

Also, we have instituted a Management Safety Review Committee (MSRC) which will provide a broad management overview of nuclear related activities and will act in an oversight role .. of independent review . *,:;, 8':-'0E:04-0229 F'DR A:OOCI< G! ::::*?(>728 050(><)2:::0 F'DC 0 , ' , *' "7 ,~ .. -, ,:;_;.'~', *. ' '*' V !*

• The increased support of the independent review functions will provide a significant enhancement to our continued efforts in improving the safe operation of our nuclear stations.

Although a Notice of Violation was not issued for Surry Power Station in IEIR 50-280&281/89-14, a violation "essentially identical to Violation A in the Notice of Violation issued with North Anna Inspection Report 50-338,339/89-14" was discussed.

This response addresses that violation as well as the subject North Anna violation.

If you have further questions, please contact us. Very truly yours, W. L. STEWART Attachments:

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 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station

' .

• RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN APRIL 18 AND MAY 31. 1989 INSPECTION REPORT NOS. 50*338/89-14 AND 50-339/89*14 NRC COMMENT VIOLATION A During the Nuclear Regulatory Commission (NRC) inspection conducted on April 18 -May 31, 1989, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13, 1988) (Enforcement Policy), the violations are listed below: A. Technical Specification 6.5.2.7 states in part that the following subjects shall be reviewed by the lndependenVOperational Event Review Group: Written safety evaluations of changes in procedures as described in the Safety Analysis Report and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(I).

This review is to verify that such changes, tests or experiments did not involve a change in the

• technical specifications or an unreviewed safety question as defined in 10 CFR 50.59(a)(2) and is accomplished by review of minutes of the Station Nuclear Safety and Operating Committee and -~e design change program. Violations, REPORTABLE EVENTS and Special Reports such as: 1. Violations of applicable codes, regulations, orders, Technical Specifications, license requirements or internal procedures or instructions having safety significance.

2. Significant operating abnormalities or deviadons from normal or expected performance or station safety-related structures, systems, or components; and 3. ALL REPORTABLE EVENTS submitted in accordance with Section 50.73 to 10 CFR Part 50 and Special Reports required by Specification 6.9.2. Review of events covered. under this paragraph shall include the results of any investigations made and recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event. Reports and meeting minutes of the Station Nuclear Safety and Operating Committee.

Contrary to the above, on May 25, 1989 that inspector determined, based on a review of the independent review program and discussions with licensee personnel, that the licensee's independent review group was not performing all of the document reviews required by Technical Specification.

This is Severity IV Violation (Supplement I) and applies to both units . Page A 1 of 3

\ ! ' ..

• NOV IEIR 50-338&339/89-14 A RESPONSE TO VIOLATION

'A' 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated. 2. REASON FOR THE VIOLATION*

This violation was caused by a lack of Management involvement with independent/operating experience review activities.

This included a failure to ensure an adequate growth of manning and resources as the independent/operating experience review requirements increased.

Also, a lack of dedication to providing this function resulted in routine diversion of the already limited resources to other activities within the Nuclear Operations Department.

• 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The following corrective actions* have been implemented to enhance the independent review

• process. *

• A study has been complefed by an outside consultant which identified improvements for the independent review process at Virginia Power.

• Additional qualified reviewers have been obtained.

Management has re_affirmed that the primary responsibility of the Director -Safety Evaluation and Control is to provide supervision of off-site independent review activities.

The requirements of the Technical Specifications were reexamined to ensure that the complete set of required documents to be indepently reviewed have been identified.

• Other utilities were surveyed to determine adequate staffing requirements.

A staffing increase has been authorized and the hiring of additional independent review personnel has been initiated.

In the interim, these positions are being filled by contract personnel.

• The backlog of independent review documents is being assessed . Page A 2 of 3

• 4. NOV IEIR 50-338&339/89-14 A CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Independent review activities are being evaluated to determine the appropriate manning and other organizational responsibilities.

Virginia Power will be performing a resource allocation study in 1989 to determine the correct staffing and organizational alignments for ensuring an effective independent review function.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Virginia Electric and Power Company is taking action to ensure the Independent Review Program enhancements are completed by October 1, 1989. At that time, our Quality Assurance department will conduct an audit to verify. that the we are in full compliance with current Technical Specifications . PageA3of3