ML18153C875
| ML18153C875 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/13/1992 |
| From: | Cline W NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Stewart W Virginia Power (Virginia Electric & Power Co) |
| Shared Package | |
| ML18153C876 | List: |
| References | |
| NUDOCS 9201270136 | |
| Download: ML18153C875 (4) | |
Text
Docket Nos. 50-280, 50-281 License Nos. DPR-32, DPR-37 JAN 13 1992 Virginia Electric and Power Company ATTN:
Mr. W. L. Stewart Senior Vice President - Nuclear 5000 Dominion Boulevard Glen Allen, VA 23060 Gentlemen:
SUBJECT:
SURRY EMERGENCY PLAN, REVISION 33 DOCKET NOS. 50-280, 50-281 Our review of the subject submittal has determined that it contains changes which appear to decrease the effectiveness of your Emergency Plan, contrary to the requirements of 10 CFR 50.54(q). That regulation specifies that a nuclear power reactor licensee shall follow and maintain in effect an emergency plan which meets the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.
Three of the changes made in Revision 33 have been found to be inconsistent with 10 CFR 50.54(q) in this respect.
The enclosure to this letter delineates the specific changes which we have,
determined to be inconsistent with the planning standards of 10 CFR 50.47(b) and/or the informational elements required by Appendix E to 10 CFR Part 50.
Although we acknowledge that the changes in question do not necessarily of themselves result in an immediate degradation of your actual emergency response capability, such changes are nevertheless unacceptable because, in addition to the regulatory bases just cited, they remove certain required elements of your emergency planning program from the Plan itself and thereby from direct NRC purview.
During a telephone conversation on January 7, 1992 with Mr. J. Kreh of my staff, Mr. E. Collins of your staff committed to appropriately correct the subject inconsistencies through issuance of Revision 34 to your Emergency Plan no later than June 30, 1992.
If your commitment in this regard is not described accurately, please notify this office immediately.
Please be reminded that 10 CFR 50.54(q) requires that proposed changes which decrease the effectiveness of your Emergency Plan shall not be implemented without application to and approval by the NRC.
However, changes may be made without NRC approval if such changes do not decrease the effectiveness of the Plan, and if the revised Plan continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
If a change is made without approval, you should furnish copies in accordance with 10 CFR 50.54(q).
In addition, any changes to your Emergency Plan Implementing 9201270136 920113 PDR ADOCK 05000280 F
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JAN 13 1992 Virginia Electric and Power Company 2
Procedures should be made in accordance with the requirements of Appendix E to 10 CFR Part 50.
Should you have any questions regarding this letter, please contact Mr. William H. Rankin of my staff on 404-331-5618.
Enclosure:
Changes Which Decrease the Effectiveness of the Surry Emergency Plan cc w/encl:
E. W. Harre 11 Vice President - Nuclear Operations Virginia Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 J. P. 0 1Hanlon Vice President - Nuclear Services Virginia Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 M. R. Kansler Station Manager Surry Power Station P. 0. Box 315 Surry, VA 23883 M. L. Bowling, Jr., Manager Nuclear Licensing Virginia Electric & Power Co.
5000 Dominion Boulevard Glen Allen, VA 23060 cc w/encl:
(cont'd on page 3)
Sincerely,
/5/
William E. Cline, Chief Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
Virginia Electric and Power Company 3
cc w/encl:
(cont'd)
Sherlock Holmes, Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, VA 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation P. 0. Box 1197 Richmond, VA 23209 Michael W. Maupin Hunton and Williams P. 0. Box 1535 Richmond, VA 23212 C. M. G. Buttery, M.D., M.P.H.
State Health Commissioner Office of the Commissioner Virginia Department of Health P. 0. Box 2448 Richmond, VA 23218 Attorney General Supreme Court Building 101 North 8th Street Richmond, VA 23219 bee w/encl:
J, Johnson, RII P. Fredrickson, RII B. Buckley, NRR Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 1, Box 166 Surry, VA 23883 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 78-A Mineral, VA 23117
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JAN 13 1992
e JAN 1 ::l 1992 ENCLOSURE CHANGES WHICH DECREASE THE EFFECTIVENESS OF THE SURRY EMERGENCY PLAN, REVISION 33
- 1.
Section 8.3 and Table 8.1 Approximately eight pages of material describing the emergency preparedness training program were deleted and replaced by a one-sentence reference to the Nuclear Power Station Emergency Preparedness Training (NPSEPT) Program Guide as the governing document in this area.
This change is unacceptable because the Emergency Plan no longer addresses the applicable regulatory requirements.
Section IV.F of Appendix E to 10 CFR Part 50 specifies that the Emergency Plan "shall include a description of specialized initial training and periodic retraining programs to be provided" to each of the various categories of emergency personnel designated therein.
- 2.
Section 8.6.1 Commitments to conduct off-hour exercises and for some to be unannounced (consistent with NUREG-0654 criterion II.N.l.b).were deleted and replaced by the following statement:
"Emergency exercises will be scheduled to start at different times of the day with advance knowledge of the time held to a minimum.
11 This change decreases the effectiveness of the Plan because the new commitment is not sufficiently specific in that the term "different times of the day 11 is vague and does not necessarily encompass off hours.
In addition, it is not self-evident that the commitment to minimize advance knowledge of the starting time is equivalent to stating that some exercises will be unannounced.
- 3.
Section 8.7 A two-page description of the program for testing and maintenance of emergency equipment was reduced to a one-sentence reference to Section 6.3 of VPAP-2601, "Maintaining Emergency Preparedness". This change decreases the effectiveness of the Plan in that it results in the following regulatory requirements no longer being met:
10 CFR 50.47(b)(8), which requires that the Emergency Plan describe how emergency facilities and equipment are maintained Section IV.E.9.d of Appendix E to 10 CFR Part 50, which requires an Emergency Plan commitment to conducting periodic communications tests (including monthly for the ENS)