ML18153B981

Responds to SALP Insp Repts 50-280/89-16 & 50-281/89-16 for May 1988 - June 1989 Re Radiological Controls & Emergency Preparedness.Requests Reconsideration of Performance Rating & Elevation of Performance to Category 2

ML18153B981
Person / Time
Site:	Surry
Issue date:	11/01/1989
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
89-728, NUDOCS 8911210308
Download: ML18153B981 (10)

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• • VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 November 1, 1989 **, n .

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• Mr. Stewart Ebneter Serial No.89-728 Regional Administrator NO/DAS U S Nuclear Regulatory Commission Docket Nos. 50-280 Region II 50-281 101 Marietta Street, N.W. Licenses Nos. DPR-32 Suite 2900 DPR-37 Atlanta, Georgia 30323

Dear Mr. Ebneter:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 RESPONSE TO* INSPECTION REPORT 50-280&281 /89-16 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Virginia Electric and Power Company has reviewed the report o'n the Systematic Assessment of Licensee Performance (SALP) for the period May l, 1988 through June 30, 1989 for Surry Power Station. On October 4, 1989, you and other members of your staff presented the Surry SALP to Corporate and Station senior management. As we stated at that time, we consider the SALP process to be a very useful and important tool for both the NRC and Virginia Electric and Power Company in assessing and improving performance and safety at our nuclear stations.

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The recognition of our strengths in the functional area of security was appreciated. We will continue to build upon those strengths. The weaknesses identified in the functional areas of Plant Operations, Maintenance/Surveillance, and Safety Assessment/Quality Verification have been recognized and corrective actions are being aggressively pursued. Such actions include increased management involvement in day-to-day activities; implementation of additional self-assessments; increased focus on attention to detail at the worker level; enhancement of the preventive maintenance program~ improvements in work process and post maintenance testing; further enhancement of operational event and root cause analysis, tracking and trending programs; and, implementation of enhanced station administrative procedures common to both Surry and North Anna.

Although we recognize that many difficulties were observed during the assessment period in the functional areas of Radiological Controls and Emergency Preparedness, we believe that reconsideration of both these performance ratings is warranted. The significant difficulties experienced in radiation protection were largely limited to early in the assessment period. When the integral performance of this area is considered, including the substantial effort to promptly implement corrective actions, we believe that a Category 2 performance rating is justified in Radiological Controls. Likewise in the functional area of Emergency Preparedness, the one significant weakness in event

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• classification identified in the initial exercise was corrected and the plan was demonstrated to be adequate during a second exercise. In addition, an extensive self-assessment of emergency preparedness was initiated during this period and a program was developed to enhance emergency preparedness capabilities. Although we recognize that program improvements are needed, we consider our overall program to be sound and more closely characterized in performance with a Category 2 performance rating.

• We request your reconsideration of the performance ratings in both Radiological Controls and Emergency Preparedness. The detailed basis for this request is provided in the attachment. If you have any questions or require additional information please contact us.

Very trruly yours, t)W.'~'s~

Stewart Senior Vice President - Power Attachment cc: U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station

ATTACHMENT 1 SURRY POWER STATION ADDITIONAL INFORMATION FOR SALP FUNCTIONAL AREAS RADIOLOGICAL CONTROLS AND EMERGENCY PREPAREDNESS

• • FUNCTIONAL AREA: RADIOLOGICAL CONTROLS We have* reviewed the programmatic weaknesses and the violations identified in the SALP report in the area of radiological controls. The _significant difficulties experienced in radiation protection primarily occurred at the end of the previous assessment period and the early part of the subject period. As you are aware, a comprehensive corrective action program was developed and implemented early in the assessment period to address these concerns. By the middle of the assessment period, we believed that our radiological programs had already attained a level of performance above that needed to meet regulatory requirements. .We believe that your assessment weighs too heavily on the events early in the period and did not adequately consider the substantial corrective actions implemented, continuing enhancements, management involvement and actual radiation protection performance during the extensive two-unit outage.

• Many initiatives have been ongoing throughout the assessment period that have helped control overall personnel exposure, reduce contaminated area, and strengthen the radiological program. Even with the extended outages on both units during this assessment period, improving trends in personnel exposure, contaminated area and personnel contamination events (PCEs) have been maintained. For PCEs, Surry performance, which bettered the industry average for 1988 (501 vs 574), continued to improve. For 1989 year-to-date, there have been only 181 PCEs in comparison to a 1989 projected industry average of 432. Such positive trends are indicative of*

extensive management involvement in the day-to-day planning of work activities to ensure the appropriate radiological controls were in place prior tb and during performance of the activity. Station performance in these areas and other key performance indicators are depicted in the attached figures. In each instance*

improvement has been accomplished in spite of the extended outages.

The following program enhancements and performance items not identified or completely addressed in the SALP, report are provided for your added consideration:

Contract health. physics technicians onsite are now programmatically assessed and trained in the area of radiological compliance. Firm and consistent.disciplinary action has been established and applied by management to reinforce the absolute necessity for employees to abide by radiological work controls.' Comprehensive internal assessments of program implementation have been and continue to be performed as part* of ongoing self-assessments. Finally, the radwaste processing and decontamination functions have been separated from health physics monitoring and control operations to increase management overview and control of each function. It is also noted that management has increased attention to station planning and work activities to reduce the time spent in radiological control areas. This increased attention is exemplified_ in the instance when management suspended work in Unit 1 containment for several days during the ou_tage to perform decontamination activities to minimize radiation worker exposure and contamination events ..

In conclusion, we believe that events early in the assessment period have weighted too heavily in determining the performance rating in this functional area. When the integral performance of this area is considered, including the substantial corrective actions and program performance through the balance of the period, we believe that a Category 2 rating is justified in Radiological Controls.

In conclusion, we believe that events early in the assessment period have weighted too heavily in determining the performance ratirig in this functional area. When the integral performance of this area is considered, including the substantial corrective actions and program performance through the balance of the pe-riod, we believe that a Category 2 rating is justified in Radiological Controls.

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FUNCTIONAL AREA: EMERGENCY PREPAREDNESS Although we recognize that program weaknesses were identified in Emergency Preparedness during the assessment period, we consider our program to be more closely characterized in performance with a Category 2 rating. Following review of the SALP report, we have the following additional items to submit for your consideration that were not identified or completely *addressed in the SALP report: Management attention to this functional area during the period included the initiation of a self-assessment program using outside expertise. This effort resulted in an enhancement program to address areas identified as needing improvement. Enhancement efforts include procedure upgrades, drill and exercise control programs, emergency response facility configuration enhancements and coordination of public information.

Management subsequently realigned the Emergency

• Preparedness reporting structure to include direct reporting to the Vice President - Nuclear Services to provide greater management awareness and control of emergency preparedness issues.

During this period several enhancements to the RAD/MET System were initiated.

Engineering was initiated for the short-term upgrade of the existing model. Activities were initiated for the replacement of the existing system with a _mo're user friendly dose assessment modeling system with associated software based on models used by the NRC. We also note that a good, professional relationship was maintained with state and local county representatives during this period.

In clarification of exercise findings, a second exercise was conducted during the assessment period because we were not satisfied with the performance demonstrated in classification of the emergency during the *November 1988 exercise. The second exercise successfully demonstrated the effectiveness of the corrective actio*ns for event

- classification. It is important to note that the scenario for the second exercise was primarily designed to challenge these corrective actions and, therefore, should not be considered minimally challenging or indicative of a lack of management commitment to the enhancement of. our emergency capabilities. It should be noted that the statement in your report that the second exercise scena~p was "minimally challenging" was the first time t_hat we were made formally awarelthis concern on the docket Inspection Reports 50-280/89-07 and 50-281/89-07 state that "the scenario adequately provided for the demonstration of the significant exercise weakness" identified from the November 1988 exercise. The second exercise demonstrated a coordinated response effort that was in accordance with regulations, plans and station procedures. We viewed the weaknesses we identified after the second exercise as part of the on-going self-assessment process and so factored them into the programmatic assessment and enhancement program.

In both exercises facility activation response times were reported to be outside our established requirements. Although this is a valid comment, it is important to note that our plan requires activation of the Emergency Response Facilities (ERFs) at the Alert stage. Therefore, our plan is more conservative than NUREG guidance which stipulates activation of the emergency operations facility(s) (EOF) within one hour following declaration of a Site Area Emergency (SAE). For *both exercises, the local EOF (LEOF) was activated before declaration of a SAE. In addition, our full staffing levels in the ERFs are significantly higher than required minimum levels for facility

functionability. Although we recognize this as a. weakness requiring our prompt correction, we believe that the key positions in each facility are manned in a timely ,

manner and the facilities are in fact ready for operation prior to our formal declaration of activation as required by our plan. We intend to correct this issue by the November 15, 1989 exercise.

Our program has historically demonstrated effective measures needed to respond to and mitigate the consequences of a station emergency. In drill and exercise situations and on the three occasions when the emergency response facilities were activated iri response to real events (once at Surry and twice at North An_na), the key aspects of the plan have been implemented effectively. We believe the fundamental elements of the program to be sound, and_ that identified weaknesses are receiving proper

• management attention. We do not believe our plan or performance during the period constituted a minimal level of emergency preparedness safety. Therefore, we request your reconsideration of the performance rating in the functional area of Emergency Preparedness. We believe that a Category 2 rating is justified.