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)

See also: IR 05000280/1989017

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

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• 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