ML20205P888
| ML20205P888 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/28/1988 |
| From: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-662, NUDOCS 8811090006 | |
| Download: ML20205P888 (7) | |
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VInorxts ELECTRIC AND Powan COMPANY RICIIMOND, VIF.OINIA 2 0 2 6I i
j October 28, 1988 l
U. S. Nuclear Regulatory Commission Serial No.88-662 Attention: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos.
50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND R INSPECTION REPORT NOS. 50-338/88-24 AND 50-339/88-24 REPLY TO THE NOTICES OF VIOLATIQN We have reviewed your letter of September 26, 1988 which referred to the inspection conducted at North Anna between August 15 - 19, 1988 and reported in Inspection Report Nos. 50-338/88-24 and 50-339/88-24.
Our responses to the Notices of Violation are attached.
We have no objection to this correspondence being made a matter of public record.
If you have any further questions, please contact us.
Very trul to s h
W. R. Cartwr J t Vice President - Nuclear Attachment cc:
U. S. Nuclear Regulatory Commission 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 I
Hr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station giiO$$00f',
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VERIFICATION OF ACCURACY 1.
Station Administrative Procedure 6.4, "Controlled Document" Holder Responsibilities.
2.
Memo for G.
E.
Kane to all station personnel dated August 18, 1988 concerning the reproduction and storage of controlled documents.
3.
Memo from T.
R.
Maddy to M.
L.
Bowling dated August 26, 1988 documenting corrective action taken as a result of using uncontrolled copies of the Telephone Directory during the augmented callout drill.
4.
The evaluation conducted to determine if on-shift operating personnel could fulfill emergency response positions until personnel could be augmented to support an accident was performed by Dave Roth, Brian McBride and Marty Bowling.
ACTION _P_LAN 1.
The Emergency Planning Coordinator will revise Table 5.1 of the Emergency Plan to require the augmentation of emergency response personnel within 60 and 90 minutes instead of the current requirement of 30 and 60 minutes.
The Plan revision will be submitted to the NRC for approval by November 30, 1938.
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RESPONSE TO THE NOTICES OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDOCTED BETWEEN AUGUST 15 - 19. 1988 INSPECTION HEPORT NOS. 50-338/88-24 AND 50-339/88-24 H_RC COP 91ENT During the Nuclear Regulatory Commission (NRC) inspection conducted on August 19,
- 1988, violations of NRC requirements were identified.
The 15 violations involved: 1) Failure to maintain a current revision of Section 1.2, Virginia Power North Anna Power Station Telephone Directory Emergency Numbers at the Security call stations.
- 2) Failure to meet augmentation staffing times for Emergency Response Personnel as committed to in Table 5.1 of the Emergency Plan.
In accordance with the "General Statement of Policy Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:
A.
10 CFR 50, Appendix B Criterion VI as implemented by the North Anna Accepted Quality Assurance Program (Topical Report Quality Assurance Program Operations Phase VEP 1-5A),
Amendment
- Five, June, 1986 (updated 1/87), Section 17.2.6, Document Control requires that a copy of the appropriate procedure be available at the activity location prior to the commencement of that activity.
Emergency Plan Implementing Procedure (EPIP) 3.01 Callout of Emergency
Response
Personnel directs the user Security Team Leader to obtain Section 1.2 of the North Anna Power Station Telephone Directory and make the notifications as rapidly as possible.
Contrary to the above, during an Augmentation Call Out Drill on August 17,
- 1988, security personnel obtained and used outdated revisions of Section 1.2 of the North Anna Power Station Telephone Directory.
This is a Severity Level V violation (Supplement VIII).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
2.
REASON FOR THE VIOLATION The violation was caused by the personnel failing to adhere to the requirements of Station Administrative Procedure (ADM) 6.4.
Personnel responsible for initiating the emergency response augmented callout drill obtained and used uncontrolled and outdated revisions of Section 1.2 of the North Anna Power Station Telephone Directory.
The reproduction and use of the Telephone Directory is in noncompliance with ADM 6.4.
a 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESb~TJ ACHIEYEQ The Station Manager issued a memorandum to all station personnel, on August 18, 1988, emphasizing the importance of the precess used for reproduction and storage of controlled documents.
65e memorandum specified the requirements of ADM 6.4 and the expectution to comply with those requirements.
The security personnel responsible fo:-
initiating the emerg'ncy response augmeated call out drill have obtained two controlled copies of Section 1.2 of the North Anna Power Station Telephone Directory tc perform future emergency response callouts.
These controlled copist are maintained and controlled by the Security Shift Supervisor.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective action is required.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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NRC C0DiENT B.
10 CFR 50.34(b)(6)(v) requires that included i r.
a final safety analysis report shall be plans for coping with emergencies which shall include the items specified in Appendix E.
10 CFR 50, Appendix E(IV) requires that the applicant's emergency 91ans shall contain information needed to demonstrate compliance wit h the elements set forth
- below, i.e.,...
activation of emergency organization, notification procedures, etc.
Table 5.1 of the Emergency Plan titled Minimum Staffing Requirements for Emergencies lists the major Functional
- areas, Major
- Tasks, Emergency Title and approximate response times for Emergency Personnel to augment on shift personnel.
Contrary to the above, based on results of an observed unannounced Augmentation Call Out Drill conducted after hours on August 17, 1988, using procedure EP-Misc-1 dated June 30, 1988, and EPIP 3.01, Rev.
17, the response times of the augmentation personnel set forth in Table 5.1 of the Site Emergency Plan were not met.
Specifically, 4 of the 11 listed personnel could not meet the 30 minute response requirement and one functional position could not be contacted by telephone during the drill.
A second unannounced drill conducted the following night on August 18, 1988, also failed to meet the 30 minute response time.
This is a Severity Level IV violation (Supplement VIII).
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RESPONSE
l 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
2.
REASON FOR THE VIOLATION The violation was caused by a failure to revise Table 5.1 of the Emergency Plan to reflect current operating practices for augmenting shift i
manning.
These current practices are believed to meet the intent of the requirements of NUREG-0654.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An evaluation of the 30 minute augmentation requirements curreatly in Table 5.1 of the Emergency Plan was conducted.
The results of this evaluation are delineated below for the eleven positions currently required to be augmented within 30 minutes, a.
1 Emergency Communicator - The additional communicator is not required immediately because in the event of an emergency each operating shift designates two operators as dedicated communicators.
These operators will continue to perform the l
communicator function until relieved by augmented emergency response personnel.
The Radiological b.
1 Radiological Assessment Director Assessment Director position is assumed immediately in the event of an emergency by the senior Health Physics representative on site.
The interim Radiological Assessment Director will perform the P.adiological Assessment Director function until relieved by augmented emergency response personnel.
Only the initial response c.
6 Health Physics Personnel responsibilities need to be performed during the first 60 minutes of an accident. The initial response to an accident involves protecting the health and safety of the public by making initial dose assessment of actual or potential releases.
The senior Health Physics person on-site assumes the position of the Radiological Assessment Director and performs the initial dose assessment.
Any necessary protective actions will be based on an assessment of plant parameters by the Radiological Assessment Director.
Access control, for the protection of the operating staff, is performed by a second on-site Health Physics technician.
A third Health Physics technician is required to provide mandatory in plant monitoring.
These three Health Physics personnel are responsible for providing support of the Emergency Plan Implementing Procedures and make up the minumum Health Physics shift manning.
The four Health Physics technicians who make up the monitoring teams are not immediately required to protect the public or plant personnel since the monitoring teams only serve as confirmation, through samples, of the levels believed to be released.
Augmenting Health Physics personnel will provide additional coverage to these already on-site Health Physics personnel.
Delaying the expected response time for augmenting emergency response personnel will not degrade the initial response that protects the health and safety of the public.
Therefore, the current duties required of i
the 6 additional Health Physics personnel in 30 minutes is already covered by the minimum on-site Health Physics shift coverage.
Any initial analysis that would be d.
1 Reactor Engineer performed by the Reactor Engineer can be performed by the Shift Technical Advisor (STA) until relieved by augmented emergency response personnel.
The STA meets the training requirements for the Reactor Engineer and routinely performs reactor engineering duties on the operating backshift, e.
2 Damage Control Team Members - Damage Control Team personnel are not immediately needed in the event of an emergency.
Emergency Procedures require unit stabilization prior to the Damage Control Team performing their function.
- Also, an
electrical and mechanical maintenance crew currently provide on-site coverage for a minimum two ten hour shifts per day.
4.
CORRECTIVE STEPS WHICH WILL JE TAKEN TO AVOID FURTHER VIOLATIONS A revision to Table 5.1 of the Emergency Plan is being developed to request a change to the 30 minute and 60 minute augmented response time t
required of emergency personnel in the event of an accident.
The Plan revision will require the designated emergency response personnel to be augmented within a 60 and 90 minute timeframe.
The Emergency Plan revision will require NRC review and approval pursuant to the requirements of 10CFR50.54(q).
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The request for the revision to Table 5.1 of the Emergency Plan will be submitted to the NRC by November 30, 1988.
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