ML18143B354

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Responds to NRC Re Violations Noted in Insp Repts 50-280/85-16 & 50-281/85-16.Corrective actions:EPIP-1.05 Reworded to Exclude Possibility of User Not Making Appropriate & Immediate Protective Action Recommendation
ML18143B354
Person / Time
Site: Surry  
Issue date: 06/26/1985
From: Stewart W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
85-429, NUDOCS 8508080678
Download: ML18143B354 (3)


Text

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WfLLL.L\\I L STEWART Vice President Nuclear Operations Nuclear Operations Department Post Office Box 26666 One fames River Plaza Ricbmond, Virginia 23261 June 26, 1985 VIRGINIA POWER Dr. J. Nelson Grace Regional Administrator Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Gentlemen:

Serial No.

NO/HLM:dn Docket Nos.

License Nos.85-429 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of May 29, 1985 in reference to the inspection conducted at Surry Power Station on April 29~Ma.;~2, 1985 and reported in IE Inspection Report Nos. 50-280/~.,.-and 50-281/85-16. Our response to the specific violation is attached.

We have determined that no proprietary information is contained in the report.

Accordingly, Virginia Power has no objection to this inspection report being made a matter of public disclosure.

The information contained in the attached pages is true and accurate to the best of my knowledge and belief.

Very truly yours, c..,,

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~ov-W. L. Stewart Attachment cc:

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Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Mr. D. J. Burke NRC Resident Inspector Surry Power Station

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8508080678 850626 PDR ADOCK 05000280 G

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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/85-16 and 50-281/85-16 VIOLATION 10 CFR 50. 54 (q) requires that nuclear power reactor licensees follow and maintain in effect emergency plans which meet the requirements of Appendix E to 10 CFR 50 and the planning standards of 10 CFR 50.47(b).

10 CFR 50.47(b)(10) requires that the licensee's emergency plans include a range of protective actions, consistent with Federal guidance, for the plume exposure pathway EPZ for emergency workers and the public.

The Federal guidance on protective actions to be recommended to offsite officials for a General Emergency is presented in Appendix 1

to NUREG-654/FEMA-REP-1.

Rev.

1, entitled "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." This guidance is clarified by IE Information Notice No. 83-28, "Criteria for Protective Action Recommendations for General Emergencies."

Both of these documents inform the licensee that sheltering of the populace to 2 miles in all directions and 5 miles downwind is to be recommended to offsite authorities promptly upon declaration of a General Emergency.

Contrary to the above, the licensee's emergency plan implementing procedures did not, under some circumstances, provide clear direction to the user to issue a protective action recommendation upon declaration of a General Emergency.

This is a Severity Level IV violation (Supplement VIII).

RESPONSE

(1)

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.

(2)

REASONS FOR VIOLATION The wording of Surry EPIP-1. 05, Step 12, a) created an opportunity for the user not to make an appropriate and immediate Protective Action Recommendation to offsite officials as provided in Step 12, b).

The parallel step in North Anna's EPIP-1.05 is worded to require the appropriate Protective Action Recommendation.

This difference in wording was not identified during the commonality review due to an oversight.

(3)

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED

  • EPIP-1. 05, Step 12, a) has been reworded to exclude the possibility of the user not making an appropriate and immediate Protective Action Recommendation to offsite offici~ls.

The review and approval process for this revision has been completed.

(4)

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Emphasis will be placed on the change to EPIP-1.05 during retraining.

(5) DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance has been achieved.