ML19263B572
| ML19263B572 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/15/1978 |
| From: | Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19263B573 | List: |
| References | |
| NUDOCS 7901220022 | |
| Download: ML19263B572 (2) | |
Text
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a VIRGINIA ELECTRIC AND POWEH COMPANY Hicurmonn,Vanornra nous December 15, 1978
'fr. James P. O'Reilly, Director Serial No. 675/112278 office of Inspection and Enforcement P0/DLB:scj U. S. Nuclear Regulatory Commission Docket N Region II License No. NPF-4 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
We have reviewed your letter of November 22, 1978 in reference to the inspection conducted at North Anna Power Station on October 17-20, 1978 and reported in IE Inspection Report No. 50-338/78-33. Our response to the specific violation in attached.
We have determined that no proprietary it. formation is contained in the report. Accordingly, the Virginia Electric and Power Company interposes no objection to the inspection report being made a matter of public disclosure.
Very truly yours,
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C. M. Stallings Vice President-Power Supply and Production Operations J
Attachment cc:
Mr. Albert Schwencer m
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7901220c q
. ). Y - 3 RESPONSE TO VIOLATION LISTED IN INSPECTION REFORT No. 50-338/78-33 NRC COMMENT Based on the results of the NRC inspection conducted on September 12-15, 1978, it appears that certain of your activities were not conducted in full compliance with NRC requirements as indicated below. These itema have been categorized as described in our correspondence to you dated December 31, 1974. Appendix B Technical Specification 5.5.1 requires, in part, that detailed written procedures, includint Jpplicable checklists and instruction, shall-be prepared and followed for all activities involved in carrying out the Environmental Technical Specifica-tions as defined in Section 5.5.4. Section 5.5.4 - (Procedures for Environmental Surveillance - Ne2 radiological) requires that all sampling programs for plankton, ' benthos', nekton, etc., will be conducted in accordance with accepted scientific procedures and in a manner amendable to statistical treatment. The accepted scientific procedures will l be reviewed by the Environmental Services Department as a service to the station. Contrary to the above, no surveillance procedures were prepared. g i This a deficiency.
RESPONSE
We do not agree that the above listed circumstances constitute a variance from the intent of the Environmental Technical Specifications and we object to the classification of this item as an item of non-compliance. Our objections were discussed with Messrs. Cunningham and Kidd during the exit interview and are summarized below. During the development of the subject Environmental Technical Specifica-tions, in discussions with representatives of the Division of Site Safety and Environmental Analysis, Environmental Projecto, it was agreed that non-radiological environmental surveillance would be conducted in accordance with accepted scientific procedures. These procedures have been in effect s inc.t the program was initiated, having been proposed by our consultant, and reviewed both verbally and during sampling operations by qualified personnel of the Environmental Services Department. It was agreed with repres(ntatives of Environmental Projects that it was not necessary that the procedures be as detailed as safety-related procedures or that a formal sign-off document be required for every surveillance activity. This was our understanding with Environmental Projects and was the intent of the Environmental Technical Specifications as implemented. We recognize that the existing section 5.5 of the Environmental Technical Specifications does not clearly codify this intent. Accordingly, we will revise section 5.5 to more clearly reflect its original intent. In light of these circumstances, we request that this notice of su,_.}}