ML18153B842
| 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
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
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
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