ML20197A826
| ML20197A826 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/18/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 86-183, NUDOCS 8605120392 | |
| Download: ML20197A826 (5) | |
Text
,
p
/
V1MOIN1A 15LECTRIC AND l'OW HM COM PANY Hicnwoxn,VtwoIMtA 2H261 sJ,,,
b b h
e w.L.srswaar vic r==.io=='
April IS, 1986 se et... orasanos.
Dr. J. Nelson Grace Serial No.86-183 Regional Administrator NAPS /JHL/aca Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 Suite 2900 License Nos. NPF-4 101 Marietta St., N.V.
Dear Dr. Grace:
VIRGINIA ELEC'11 TIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS NO. 1 AND 2 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-338/86-05 AND 50-339/86-05 Ve have reviewed your letter of March 20, 1986, in reference to the inspection conducted at North Anna Power Station from February 24, 1986 to February 28, 1986, and reported in Inspection Report Nos. 50-338/86-05 and 50-339/86-05.
Our response to the Notice of Violation is addressed in the attachment.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact me.
Very truly yours, n.
r
- ~
\\ ';
\\q)!q ;}%: y W. L. Stewart Attachment kh DO k
G D
vamosuu Es.scTaic no Pows Commxy to Dr. J. NeIson Grace cc:
Mr. Roger D. Walker, Director Division of Reactor Projects NRC Region II Mr. Virgil L. Brownlee, Chief Reactor Projects Branch 3 Division of Reactor Projects NRC Region II Mr. Lester S. Rubenstein Director PWR Project Directorate #2 Division of PWR Licensing-A Mr. Larry King
'NRC_ Resident Inspector North Anna Power Station Mr. Leon B. Engle NRC North Anna Project Manager PWR Project Directorate #2 Division of PWR Licensing-A
RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM FEBRUARY 24, 1986 TO FEBRUARY 28, 1986 INSPECTION REPORT NOS. 50-338/86-05 AND 50-339/86-05 NRC COMMENT:
10 CFR 50.54(q) states that a nuclear power reactor licensee shall follow and maintain in effect an emergency plan which meets the requirements of Appendix E to 10 CFR Part 50.
Section IV.F of Appendix E requires that a licensee's emergency plan describe specialized initial training and periodic retraining programs for various categories of emergency personnel, including repair and damage control teams.
Contrary to the above, the licensee's Emergency Plan failed to describe a specialized training program for the Damage Control Team.
- Moreover, no specialized emergency training for such personnel could be identified in the licensee's training program.
This is a Severity Level V violation (Supplement VIII).
RESPONSE
1, ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is denied on the basis that our training program provides for the instruction and qualification of Damage control Team personnel who will implement radiological emergency response plans.
The North Anna Emergency Plan has been established to comply with Appendix E to 10CFR50 and describes, in general terms, the training that is provided to the Damage Control Team.
The specific details of the program are provided below.
The duties and responsibilities of the Damage Control Team are described in the Emergency Plan wherein it is stated:
"The Team will perform emergency repairs as required." The manner in which these duties are to be 'mplemented are described in Emergency Plan Implementing Procedure (EPIP) 5.08, " Damage Control Guideline".
EPIP 5.08 deffnes for the Emergency Maintenance Director (EMD), who directs the Damage Control Team, specific duties and actions including, 1) Assessment and Repair,
- 2) Contamination Control, 3) Modifications, 4) Radwaste Considerations,
- 5) Radiological liazards, 6) Task Ingress and Egress Routes, 7)
Communicaticns and 8) Team Leader Briefings. Damage Control Team members are selected by the EMD based on individual expertise, allowable dosage, task requirements, etc. as required by EPIP 5.08.
Training requirements for Damage Control Team members are defined in 1
Section 8 of the horth Anna Emergency Plan.
The plan states, in part,
" Emergency preparedness of station personnel is maintained through an 1
i i
1
-n,,-
.__,-_.n._
n--,
integrated emergency training program that includes Nuclear Power Station General Employee Training for all persons badged at the station and detailed training for persons with specific assigned functions during an emergency.
Many personnel, such as Fire, First Aid, Search and Rescue, Security, and Damage Control Team members receive emergency training as part of their normal job." Thus the plan recognizes that Damage Control Team member duties during emergencies are similar to their normal job duties and required job skills.
For the Emergency Maintenance Director annual training consists of General Employee Retraining as well as key emergency plan implementing procedures.
During the emergency plan exercise, the Emergency Maintenance Director implements EPIP 5.08.
For Damage Control Team members annual training consists of General Employee Retraining as well as functional training in their normal job duties which is received as part of the continuing job training program.
The General Employee Training and Retraining program that is provided to personnel allowed unescorted access to the station includes an emergency preparedness training overview which addresses the following:
- 1) General scope and overview of the Emergency Plan
- 2) Station Emergency Alarm and ans;uncements
- 3) Response to station Emergency Alarms
- 4) Personnel accountability
- 5) Visitor control during an emergency
- 6) Site evacuation
- 7) Emergency Plan Implementing Procedures
- 8) Emergency Organization
- 9) Emergency Control Centers (Emergency Response Facilities)
- 10) Emergency Action Levels In addition, the General Employee Training and Retraining program includes radiation protection training which addresses the following:
- 1) Radiation fundamentals
- 2) Risks and biological effects
- 3) Dose limits (normal and emergency exposures)
- 4) Dosimeter use (including type radiation measured)
- 5) ALARA concepts
- 6) Radiological Instrumentation (portable radiation monitors, area monitors and portal monitors)
- 7) Designated radiological areas (types and hazards associated with each)
- 8) Contamination (types, surveys, control of and protection requirements)
- 9) Airborne radioactivity (posting requirements, MPC, protection against dispersion and protection against personnel uptake)
- 10) Radioactive material control
- 11) Radiological waste disposal
- 12) Radiation work permits (how they are completed, where they are found, and how to use them)
The General Employee Training program along with normal job training constitute the integrated emergency training program.
This integrated (specialized) training prcgram satisfies the approved emergency plan training requirements for damage control team members.
Records of training for Damage Control Team members are available at the station.
2.
REASONS FOR THE VIOLATION:
Not applicable.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Not applicable.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Not applicable.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Not applicable.